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Found 51 results
510(k) Data Aggregation
(301 days)
The KLS Martin Drill-Free MMF Screw is indicated for temporary stabilization of mandibular and maxillary fractures to maintain proper occlusion during surgery in adults and adolescents (age 12 and older) in whom permanent teeth have erupted.
The KLS Martin Drill-Free MMF Screw are bone-borne, self-drilling screws for maxillomandibular fixation (MMF). The screws are intended to provide stabilization of mandibular and maxillary fractures as well as maintain proper occlusion during intraoneralive bone fixation. These screws may be applied prior to or after exposure of the Drill Free MMF Screw is manufactured from stainless steel (ASTM F138) with a head designed with a hole to allow passing and securing ligature wire during the procedure and is available in threaded lengths of 2.0 x 8.0 mm - 2.0 x 12.0mm. Implants are available both sterile and non-sterile.
This document is a 510(k) Premarket Notification summary from the FDA for a medical device called the "KLS Martin Drill-Free MMF Screw". It is specifically a clearance letter and a summary of the device and its equivalence to a predicate device.
Based on the provided text, the device is a mechanical implant (a screw for bone fixation), not a software-based AI/ML medical device. Therefore, the questions related to AI/ML acceptance criteria, ground truth establishment, training data, MRMC studies, and effect sizes are not applicable to this documentation.
The document describes the non-clinical performance data used to demonstrate substantial equivalence for this mechanical device.
Here's an analysis of the provided information, focusing on the mechanical device's testing:
1. A table of acceptance criteria and the reported device performance.
The document states that comparisons were made to a primary predicate device (KLS Martin Drill Free MMF Screw (K083432)) and reference devices. It describes the type of tests performed, but does not provide specific numerical acceptance criteria or the reported device performance metrics in a tabular format within this summary.
Types of Tests Mentioned:
- Comparative head-to-head static and dynamic bench testing: Conducted on the subject device and the primary predicate device to determine equivalent performance.
- Comparative screw testing: Performed to evaluate:
- Torsional strength
- Drive torque
- Pullout strength
- Biological safety risk assessments: In compliance with ISO 10993-1:2018.
- LAL endotoxin testing: To address the presence of bacterial endotoxins and meet pyrogen limit specifications in accordance with ANSI/AAMI ST72:2019.
- Gamma sterilization process validation: In accordance with ISO 11137-1:2015 and ISO 11137-2:2015 using the VDmax25 method, and also ISO 11737-1:2018 and ISO 11737-2:2019.
- Packaging validations: Performed for the PETG blister pack with 1073B Tyvek cover in accordance with ISO 11607-1 and ASTM D7386.
Reported Device Performance (General Statement):
"Mechanical test results demonstrate that KLS Martin MMF Screw's performance is substantially equivalent to the primary predicate device."
"Biological safety risk assessments... concluded the devices are biocompatible and appropriate for their intended use."
"LAL endotoxin testing... meet pyrogen limit specifications."
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective).
The document does not specify the sample sizes used for the bench testing (e.g., number of screws tested for torsional strength, number of packaging units for validation). The provenance is "Non-Clinical Performance Data," implying lab testing rather than patient data. Country of origin for data is not mentioned, but the applicant and correspondent are KLS-Martin L.P. in Jacksonville, Florida, United States. These are bench tests, not clinical studies.
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 question is not applicable. Ground truth for mechanical performance is established through physical measurements and adherence to engineering standards (e.g., ASTM, ISO). There are no "experts" in the sense of clinicians establishing ground truth from medical images for this type of device.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set.
This question is not applicable as this is a mechanical device, not an AI/ML system requiring human annotation adjudication.
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.
This question is not applicable. This is a mechanical device, not an AI-assisted diagnostic tool. No MRMC study was performed or required.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done.
This question is not applicable. This is a mechanical device.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc).
For this mechanical device, the "ground truth" for performance is based on established engineering standards and physical measurements (e.g., force, torque, material properties) as defined by ASTM and ISO standards, and comparison to the predicate device's measured performance. Biosafety is determined by established biological test methods (e.g., LAL, biocompatibility assays).
8. The sample size for the training set.
This question is not applicable. This is a physical device, not an AI model that requires a training set.
9. How the ground truth for the training set was established.
This question is not applicable. As above, there is no AI training set for this device.
Ask a specific question about this device
(98 days)
KLS Mini Osteosynthesis System (K943347): The KLS Mini Osteosynthesis System is indicated for 1) Fractures, 3) Reconstruction procedures of the craniomaxillofial skeletal system.
KLS Chin Plate System (K943348): The KLS Chin Plate System is indicated for 1) Fractures, 3) Reconstruction procedures of the craniomaxillofacial skeletal system.
KLS-Martin Micro Osteosynthesis System (1.0MM) (K944561): The KLS-Martin Micro Osteosynthesis System (1.0MM) is used in oral-maxillo-cranio-facial surgery to stabilize fractures. The bone segments are attached to the plate with screws to prevent movement of the segments.
KLS-Martin Micro Osteosynthesis System (1.5MM) (K944565): The KLS-Martin Micro Osteosynthesis System (1.5MM) is used in oral-maxillo-cranio-facial surgery to stabilize fractures. The bone segments are attached to the plate with screws to prevent movement of the segments.
KLS Martin Centre-Drive Drill-Free Screw (K971297): The KLS Martin Centre-Drive Drill-Free Screws are in rigid internal fixation of the oral-maxillo-cranio-facial bones. The bone screws are used to anchor plates which are contoured to fit the bone fragments. The addition of the self drilling feature is the only difference between the submitted device and the predicate device referenced.
KLS-Martin Temporary Condylar Implant (K990667): The KLS-Martin Temporary Condylar Implant is only intended for temporary reconstruction of the mandibular condyle in patients who have undergone resective procedures to remove malignant or benign the removal of the mandibular condyle. This device is not for permanent implantation, for patients with TMF or treatment of temporomandibular joint disease (TMD).
KLS-Martin Mandibular/Reconstruction System II (K032442): The KLS-Martin Mandibular/Reconstruction System II is intended for use in the stabilization of mandibular fractures and mandibular reconstruction.
KLS-Martin Ortho Anchorage System (K033483): The KLS-Martin Ortho Anchorage System is intended to be surgically placed in the mouth for use an an anchor for orthodontic procedures.
KLS-Martin Ortho Anchorage System (Plates) (K040891): The KLS-Martin Ortho Anchorage System (Plates) are implants intended to be surgically placed in the mouth for use as an anchor for orthodontic procedures in patients.
KLS Martin Rigid Fixation - Sterile (K060177): The KLS Martin Rigid Fixation - Sterile is in sterile packaging, osteosynthesis products with the following indications for use:
K051236: The RESORB-X® SF Sonotrode is only intended for use for insertion of the RESORB-X® SF pins.
K032442: The KLS Martin Mandibular/Reconstruction System II is intended for use in the stabilization of mandibular fractures and mandibular reconstruction.
K971297: The KLS Martin Centre-Drive Drill-Free screws are in rigid internal fixation of the oral-maxillo-cranio-facial bones. The bone screws are used to anchor plates which are contoured to fit the bony surface and stabilize the bone fragments. The addition of the self drilling feature is the only difference between the predicate device reference
K944565: The KLS-Martin Micro Osteosynthesis System is used in oral-maxillo-cranio-facial surgery to stabilize fractured bone segments. The bone segments are attached to the plate with screws to prevent movement of the segments.
K944561: The KLS-Martin Micro Osteosynthesis System is used in oral-maxillo-cranio-facial surgery to stabilize fractured bone segments. The bone segments are attached to the plate with screws to prevent movement of the segments.
KLS Martin Drill-Free MMF Screw (K042573): The KLS Martin Drill-Free MMF Screws is intended for use in maxilonandibular fixation of fractures of the maxilla, mandible, or both.
Drill Free MMF Screw (K083432): The Drill Free MMF Screw is intended for use in maxillomandibular fixation of fractures of the maxilla, mandible, or both.
KLS Martin L1 MMF System (K173320): The KLS Martin L1 MMF System is intended for temporary stabilization of maxillary fractures. It is designed to maintain proper occlusion during intraoperative bone healing (app. 6-8 weeks). It is indicated for the temporary treatment of maxillomandibular fixation (MMF) in adults or adolescents who have permanent teeth present (ages 12 and older).
KLS Mini Osteosynthesis System (K943347): The KLS Mini Osteosynthesis System consists of titanium non-locking plates ranging in thickness from 0.6mm - 2.5mm and titanium screws ranging in diameter from 1.5mm - 2.3mm.
KLS Chin Plate System (K943348): The KLS Chin Plate System consists of titanium plates ranging in thickness of 0.6mm and titanium screws ranging in diameter from 1.5mm - 2.3mm.
KLS-Martin Micro Osteosynthesis System (1.0mm) (K944561): The KLS-Martin Micro Osteosynthesis System is designed to aid in the alignment and stabilization of the skeletal system after a facial fracture or surgery. The bone plates, bone plates, bone screws and accessories of various shapes and sizes for use in oral-maxillo-cranio-facial surgery. The bone plates are manufactured from CP Titanium and range in thickness from 0.3mm - 0.6mm. The bone screws are manufactured from Titanium Alloy and range in diameter from 1.0mm - 1.2mm.
KLS-Martin Micro Osteosynthesis System (1.5mm) (K944565): The KLS-Martin Micro Osteosynthesis System is designed to aid in the alignment and stabilization of the skeletal system after a facial fracture or surgery. The bone plates and screws of various shapes and sizes for use in oralmaxillo-cranio-facial surgery. The bone plates are manufactured from CP Titanium and range in thickness from 0.3mm - 0.6mm. The bone screws are manufactured from Titanium Alloy and range in diameter from 1.5mm - 1.8mm.
KLS Martin Centre-Drive Drill-Free Screw (K971297): The KLS Martin Centre-Drive Drill-Free Screws are designed to eliminate the need for pre-drilled pilot holes. They are self-tapping with one step insertion. They are intended for use in rigid internal fixation of the oral-maxillo-cranio-facial bones. The bone screws are used to anchor plates where are contoured to fit the bone fragments. The bone fragments. The bone screws are manufactured from Titanium Alloy and range in diameter from 1.0mm - 2.0mm.
KLS-Martin Temporary Condylar Implant (K990667): The KLS-Martin Temporary Condylar Implant is a solid condylar head which attaches with fastening screws to a KLS-Martin Fracture/ Reconstruction Plate. The implant is available for left and right placement. The KLS-Martin Temporary Condy intended for temporary reconstruction of the mandibular condyle in patients who have undergone resective procedures to benign tumors requiring the removal of the mandibular condyle. This device is not for permanent implantation, for patients with TMJ or traumatic injuries, or for treatment of temporomandibular joint disease (TMD).
KLS-Martin Mandibular/Reconstruction System II (K032442): The KLS-Martin Mandibular/Reconstruction System II includes several different designs of titanium plates and screws intended for use in the stabilization and fixation of mandibular fractures and reconstruction. The plates are manufactured from either CP Titanium or Titanium Alloy and range in thickness from 1.0mm - 3.0mm. The screws are manufactured from either CP Titanium Alloy and range in diameter from 2.0mm - 3.2mm.
KLS-Martin Ortho Anchorage System (K033483): The KLS-Martin Ortho Anchorage System consists of a titanium screw designed to aid in dental movement by providing a rigid skeletal fixation point. The screw is intended to be surgically placed in the mouth for orthodontic procedures. The screws are manufactured from either CP Titanium or Titanium Alloy.
KLS-Martin Ortho Anchorage System (Plates) (K040891): The KLS-Martin Ortho Anchorage System (Plates) consists of titanium non-locking plates to aid in dental movement by providing a rigid skeletal fixation point. The plates are manufactured from either CP Titanium Alloy and are fixated with titanium screws and are utilized as an anchor for orthodontic procedures in the palatal, maxilla or mandible region.
KLS-Martin Drill-Free MMF Screw (K042573): The KLS-Martin Drill-Free MMF Screw provides temporary occlusal and fracture stabilization. These screws may be applied prior to or after exposure of the fracture. The KLS-Martin Drill-Free MMF Screw is in maxillomandibular fixation to provide stabilization of fractures of the maxilla, or both. The screws are manufactured from either CP Titanium Alloy and are provided in 2.0mm diameter with lengths ranging from 8mm - 12mm.
KLS Martin Rigid Fixation - Sterile (K060177): The KLS Martin Rigid Fixation - Sterile includes titanium plates of various shapes and thickness, titanium screws of various length and diameter, stainless steel twist drills of various length and stainless steel sonotrode tips that are provided in sterile packaging. The KLS Martin Rigid Fixation - Sterile is intended to provide KLS Martin's previously cleared osteosynthesis products in sterile packaging.
Drill Free MMF Screw (K083432): The Drill Free MMF Screw provides temporary occlusal and fracture stabilization. These screws may be applied prior to or after exposure of the fracture. The Drill Free MMF Screw is in maxillomandibular fixation to provide stabilization of fractures of the maxilla, mandible, or both. The screws are manufactured from Stainless Steel and are provided in 2.0mm diameter with lengths ranging from 8mm - 12mm.
KLS Martin L1 MMF System (K173320): The KLS Martin L1 MMF System is a bone-borne maxillomandibular fixation (MMF) system consisting of metalic archbars with sliding locking plates that attach to the dental arches with screws. The system is intended to provide temporary stabilization of mandibular and maxillary fractures as well as maintain properative bone fixation and postoperative bone healing (app. 6-8 weeks). The patient is brought into occlusion by wiring around the archbar wire hooks. The L1 MMF system plates are manufactured from CP Titanium (ASTM F67), are available in either a 7-hole siding plate configuration with two different lengths, and are 0.5mm in plate thickness. The L1 MMF system sliding locking plates are fixated with either 2.0 x 6 mm selfdrilling locking screws manufactured from Ti-6Al-4V (ASTM F136). Implants are available both sterile. The system also includes the necessary instruments to facilitate placement of the implants.
The document describes the KLS Martin Oral-Max Implants - MR Conditional, a bundled submission of various osteosynthesis systems and screws intended for use in craniomaxillofacial surgery. The purpose of this submission is to support the conditional safety and labeling modification of these devices in the magnetic resonance (MR) environment.
Here's an analysis of the acceptance criteria and the study that proves the device meets them:
1. A table of acceptance criteria and the reported device performance
The acceptance criteria are implied by the non-clinical tests conducted to support MR Conditional safety, aligning with relevant ASTM standards and FDA guidance. The reported device performance is that the devices can be safely scanned under specified conditions.
| Acceptance Criteria (from ASTM/FDA Guidance) | Reported Device Performance (Summary from Submission) |
|---|---|
| Magnetically induced displacement force within acceptable limits (ASTM F2052-21) | Not explicitly quantified but implied as acceptable for MR Conditional labeling. |
| Magnetically induced torque within acceptable limits (ASTM F2213-17) | Not explicitly quantified but implied as acceptable for MR Conditional labeling. |
| Image artifacts within acceptable limits (ASTM F2119-07, R2013) | Not explicitly quantified but implied as acceptable for MR Conditional labeling. |
| RF-induced heating (ASTM F2182-19e2) resulting in a temperature rise below 6 ℃ | Achieved under specified scanning conditions: 1.5 T/64 MHz and 3 T/128 MHz at a whole-body averaged specific absorption rate (wbSAR) of 2 W/kg or head SAR of 3.2 W/kg for an hour-long scanning session. |
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
The testing involved computational modeling and simulation (CM&S). The "test set" in this context refers to the simulated scenarios and device configurations.
- Sample Size for Test Set: "the entire portfolio of KLS Martin maxillofacial implants" was simulated. This implies that all devices grouped under "KLS Martin Oral-Max Implants - MR Conditional" were included in the simulations. The document also mentions "various in-vivo device positions and landmarks," "worst-case single and multiple devices," and simulations in "10 cm increments." This suggests a comprehensive set of simulated scenarios rather than a traditional physical sample size.
- Data Provenance: Not explicitly stated as "country of origin" or "retrospective/prospective" in the same way clinical data is. The data is generated through computational modeling and simulation using MED Institute's FDA-qualified Medical Device Development Tool (MDDT) and the Duke virtual human anatomy. This is a form of prospective simulation data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable in the traditional sense for this type of non-clinical, simulation-based study. The "ground truth" for the RF-induced heating simulations is derived from the established physics and engineering principles embedded in the FDA-qualified MDDT and the Duke virtual human anatomy model. The expertise lies in the development and validation of these computational tools and the interpretation of the simulation results by experts in MR safety and medical device engineering at MED Institute and the submitting company. The document does not specify the number or qualifications of individual experts validating the computational model, but implies that the MDDT itself is "FDA-qualified," indicating a level of expert review and agreement on its methodology.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
Not applicable. Adjudication methods like "2+1" or "3+1" are typically used for consensus building among human expert readers for clinical studies, especially when establishing ground truth from image interpretation. This study is based on physical property testing and computational simulations, not human interpretation of clinical data.
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
Not applicable. This is not a study involving human readers or AI-assisted diagnostic performance. It focuses on the physical safety of implants in an MR environment.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
The RF-induced heating assessment involved "Computational modeling and simulation (CM&S) ... using MED Institute's FDA-qualified Medical Device Development Tool (MDDT) and in a clinically relevant position within the Duke virtual human anatomy." This is a standalone algorithm/model-based assessment without a human-in-the-loop for the performance evaluation itself. Human experts design the simulations, configure the models, and interpret the results, but the "performance" (temperature rise, SAR calculations) is computed by the algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For the non-clinical tests:
- Magnetically induced displacement force, torque, and image artifacts: The "ground truth" is based on the physical properties of the materials and device designs, measured or calculated according to established ASTM standards (F2052-21, F2213-17, F2119-07).
- RF-induced heating: The "ground truth" for the simulations is derived from the established electromagnetic physics and thermal dynamics principles implemented in the FDA-qualified Medical Device Development Tool (MDDT) and applied to the Duke virtual human anatomy model. The MDDT's qualification process by the FDA implicitly establishes the reliability of its results as a form of "ground truth" for simulation-based assessments.
8. The sample size for the training set
Not applicable. This is a non-clinical study for MR safety assessment, not a machine learning model requiring a training set in the typical sense. The "training" for the MDDT is its initial validation and qualification against known physical phenomena and experimental data, which is a separate process from this submission.
9. How the ground truth for the training set was established
Not applicable, as there is no training set for a machine learning model in this context. The "ground truth" for qualifying the simulation tool (MDDT) would have been established through extensive validation against experimental measurements and recognized physical theories.
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(88 days)
KLS Martin Sternal Plating System (K032413): The KLS Martin Sternal Plating System is intended for use in stabilization of anterior chest wall fractures including sternal fixation subsequent to sternotomy and sternal reconstructive procedures.
KLS Martin Hand Plating System (K040598): The KLS Martin Hand Plating System is used for stabilization of fractures, revision procedures, joint fusion and reconstruction of small bones of the hand, wrist, fingers, feet, ankles and toes.
KLS Martin Sternal Talon (K051165): The KLS Martin Sternal Talon is intended for use in stabilization of anterior chest wall fractures including sternal fixation subsequent to sternal reconstructive procedures.
KLS Martin Sternal Talon & KLS Martin Sternal Plating System - Sterile (K070169): To offer KLS Martin Sternal Talon and KLS Martin Sternal Plating in sterile packaging with the following indications for use: K051165 KLS Martin Sternal Talon and K032413 KLS Martin Sternal Plating System are intended for use in stabilization of anterior chest wall fractures including sternal fixation subsequent to sternotomy and sternal reconstructive procedures.
Recon Talon (K122860): The KLS Martin Recon Talon is intended for use in stabilization and fixation of anterior chest wall fractures including sternal fixation subsequent to sternal reconstructive procedures.
LINOS MOH Hand Plating System (K141489): The LINOS MOH Hand Plating System is used for stabilization of fractures, revision procedures, joint fusion and reconstruction of small bones of the hand, wrist, fingers, feet, ankles and toes.
KLS Martin LSS Plating System (K151983): The KLS Martin LSS Plating System is to be used in conjunction with sternal closure wire for use in primary or secondary closure/repair of the sternum following sternotomy and is intended to reinforce the sternal halves and distribute wire tension.
KLS Martin Thoracic Plating System (K153482): The KLS Martin Thoracic Plating System is indicated for use in the stabilization and fixation of fractures in the chest wall including sternal reconstructive surgical procedures, trauma, or planned osteotomies.
KLS Martin Cannulated Headless Screws (K161259): KLS Martin Cannulated Headless Screws are intended for the treatment of fractures, osteotomies, arthrodeses, and nonunions of small bones in the hand, wrist, foot, and ankle.
Level One Hand Plating System (K170124): The Level One Hand Plating System is used for stabilization of fractures, revision procedures, joint fusion and reconstruction of small bones of the hand, wrist, fingers, feet, ankles and toes.
KLS Martin Pure Pectus System (K221938): The KLS Martin Pure Pectus System is indicated for use in surgical procedures to repair pectus excavatum. It is indicated for use in adult and pediatric (children and adolescents) populations.
KLS Martin Level One Rib Fixation System (K222397): The KLS Martin Level One Rib Fixation System is indicated for use in the stabilization and rigid fixation of rib fractures in the chest wall including reconstructive procedures, trauma, or planned osteotomies in patients 18 years of age or older.
KLS Martin LINOS Wrist System (K222624): The KLS Martin LINOS Wrist System is indicated for use in forearm fractures, osteotomies, and arthrodeses. It is intended for adults, and children (2-12 years) and adolescents (12-21 years) in which growth plates have fused or in which growth plates will not be crossed by fixation.
The KLS Martin Sternal Plating System consists of titanium plates ranging in thickness from 1.0mm – 3.0mm and screws ranging in diameter from 2.3mm – 3.2mm.
The KLS Martin Hand Plating System consists of titanium plates ranging in thickness from 0.6mm – 3.0mm and screws ranging in diameter from 1.0mm – 2.7mm.
The KLS Martin Sternal Talon is a two-piece with various foot depths and lengths that utilizes a ratcheted locking system. Each piece of the device is placed on opposing sides of the sternum and is designed to interlock providing a stabilized fixation thus allowing for various sternal widths. The device has a three-position screw which allows the ratchet to open, close and lock. In an emergency situation, the device can be reopened by turning the screw to the open position. A second emergency re-entry is provided by cut points adjacent to the screw. The KLS Martin Sternal Talon is manufactured from titanium alloy (Ti-6Al-4V).
The KLS Martin Sternal Talon (K051165) is a two-piece with various foot depths and lengths that utilizes a ratcheted locking system. Each piece of the device is placed on opposing sides of the sternum and is designed to interlock providing a stabilized fixation thus allowing for various sternal widths. The device has a three-position screw which allows the ratchet to open, close and lock. In an emergency situation, the device can be reopened by turning the screw to the open position. A second emergency re-entry is provided by cut points adjacent to the KLS Martin Sternal Talon is manufactured from titanium alloy (T-6Al-4V). The KLS Martin Sternal Plating System (K032413) consists of titanium plates rom 1.0mm – 3.0mm and screws ranging in diameter from 2.3mm - 3.2mm. The screws are used to affix the plates to the sternum. Plate an elongated midsection to facilitate quick re-entry in subsequent thoracic procedures.
The KLS Martin Recon Talon is a two-piece clamping device, which has on either end an attached plate. Plate thickness ranges from 1.0mm to 3.0mm and screw diameter ranges from 2.2mm. The two-piece clamping device utilizes a ratcheted locking system. Each piece of the device is affixed to opposing sides of the sternum and interlocks to provide stablized fixation. The device has a threeposition screw, allowing the ratchet to open, close, and lock. In an emergency situation the device can be reopened by turning the screw to the open position. Secondary emergency re-entry is provided by cut points adjacent to the screw.
The LINOS MOH Hand Plating System consists of titanium plates ranging in thickness from 0.6mm – 3.0mm and screws ranging in diameter from 1.0mm – 2.7mm. Plate features include a low profile with anqulated-locking threaded screws are either locking or non-locking.
The KLS Martin LSS Plating System includes plates and screws that are in conjunction with stainless steel suture wire for midline sternal closure. The LSS plates, when applied, are used to reinforce the sternal halves and mitigate the chance of sternal wire pulling through bone. The plates are manufactured from PEEK and offered in one size. The thickness from 2.1 mm – 2.5 mm (minimum – maximum dimensions) and are fixated using 2.3mm titanium screws. Once the sternum is reapproximated, the midline is closed using circumferentially wrapped stainless steel suture wires. Emergent re-entry is accomplished by cutting the stainless steel suture wire.
The KLS Martin Thoracic Plating System includes metallic plates and screws that provide rigid fixation to fractures, and can be used for reconstructive procedures in the thoracic anatomy. The implants are available non-sterile in multiple shapes and sizes. Plates are manufactured from CP Titanium (ASTM F67:2013) and range in thickness from 1.0 – 3.0mm. Screws are manufactured from Ti-6Al-4V (ASTM F1362013) and range in diameter from 2.3 – 3.2mm with lengths from 7 – 17mm.
The KLS Martin Cannulated Headless Screws (CHS) system is comprised of headless cannulated screws intended for bone fixation in the treatment of fractures, non-unions, osteotomies, or to aid in small joint fusions of the hand, wrist, foot, and ankle. Bone fixation is achieved by proximal and distal threads designed with different pitches that, when inserted into the bone, cause compression of the bone fragments for bone reduction, stability, and healing. Cannulation of the user to inow the user to insert the screw over the guide wire for proper placement prior to compression. The CHS system offers screws in various diameters, overall lengths, and thread lengths to accommodate different sizes and types of bone reduction, such as scaphoid fractures and non-unions. The screws are self drilling and self-tapping to eliminate the need for do implantation. All screws are manufactured from Ti-6Al-4V (ASTM F136:2013).
The Level One (L1) Hand Plating System includes metallic plates, washers, and screws intended for small bone fixation. Plates are precontoured to accommodate patient anatomy, available in various shapes and range in thickness from 0.6mm - 3.0mm and are compatible with the standard and multidirectional locking screws offered in the system. Screws are self tapping, available in a standard or multidirectional locking configuration and range in diameter from 1.0mm - 2.7mm with lengths from 2mm - 32mm. Standard screws may be used alone or in conjunction with the washers or plates for small fragment osteosynthesis. Implants are manufactured from CP Titanium (ASTM F67) or Ti-6Al-4V (ASTM F136).
The KLS Martin LP Pure Pectus system consists of metallic implants comprised of straight and angled pers that provide support to the thoracic cavity undergoing repair for pectus excavatum. The implants are in multiple sizes and are manufactured using tradition methods. Pectus bars are manufactured from CP Titanium. Connector bars are manufactured from Ti-6Al-4V. The system also instruments to facilitate placement of the implants.
The KLS Martin Level One Rib Fixation System is comprised of PEEK plates and titanium locking screws intended to provide rigid fixation of bone in the thoracic anatomy. The PEEK plates are pre-contoured to accommodate patient anatomy and are offered in plate thicknesses of 2 mm - 3 mm. The PEEK plates are compatible with the Ti-6Al-4V (ASTM Fl 36) 2.3 mm x 7 mm multidirectional locking screws offered in the system. The plates are manufactured from PEEK (ASTM F2026). The system includes the necessary instrumentation to facilitate implantation.
The KLS Martin LINOS Wrist System consists of metallic plates used in conjunction with bone screws and locking pins intended for the internal fixation, alignment, stabilization, and/or corrective osteotomies of the distal radius and/or ulna. Plates are manufactured from Ti-6Al-4V or CP Titanium. Plates are pre-contoured to accommodate patient anatomy and are available in various shapes and dimensions. The system also includes the necessary instruments to facilitate placement of the implants.
The provided text discusses the KLS Martin Orthopedic Implants - MR Conditional device and the studies conducted to support its conditional safety in a Magnetic Resonance (MR) environment.
Here's a breakdown of the requested information based on the provided text:
1. A table of acceptance criteria and the reported device performance
| Acceptance Criteria (Hazard addressed) | Standard/Method | Reported Device Performance |
|---|---|---|
| Magnetically induced displacement force | ASTM F2052-21 | Non-clinical testing provided to support conditional safety in MR environment. (Implied acceptability based on submission) |
| Magnetically induced torque | ASTM F2213-17 | Non-clinical testing provided to support conditional safety in MR environment. (Implied acceptability based on submission) |
| Image artifacts | ASTM F2119-07, R2013 | Non-clinical testing provided to support conditional safety in MR environment. (Implied acceptability based on submission) |
| RF-induced heating | ASTM F2182-19e2 (with Computational modeling and simulation) | Temperature rise below 6°C for an hour-long scanning session at a whole-body averaged specific absorption rate (wbSAR) of 2 W/kg (or head SAR for relevant regions). |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The text does not specify a "test set" in the traditional sense of a clinical or observational study with a certain number of patients or cases. Instead, the performance evaluation is based on non-clinical testing and computational modeling and simulation (CM&S) of the devices themselves.
- Sample size for non-clinical testing: The text refers to "the entire portfolio of KLS Martin thoracic and hand osteosynthesis implants." While not a specific number, it implies a comprehensive evaluation of the range of devices.
- Data provenance: The studies are non-clinical, done ex-vivo (for some tests) and through simulation. The computational modeling utilized "MED Institute's FDA-qualified Medical Development Tool (MDDT) and in a clinically relevant position within the Duke virtual human anatomy." This suggests the data is generated through established scientific methods rather than patient data from a specific country or retrospective/prospective collection.
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 question is not applicable in the context of this submission. The "ground truth" for non-clinical testing and simulation is defined by the physical properties of the materials, the established testing standards (ASTM), and the validated computational models. There were no human experts establishing ground truth for evaluating the device's MR compatibility in the way radiology images would be reviewed.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This question is not applicable as there was no human adjudication of a clinical test set. The evaluation relies on standardized testing protocols and validated computational models.
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
This question is not applicable. This submission is for the MR Conditional labeling of orthopedic implants, not an AI-powered diagnostic device. Therefore, no MRMC study or AI assistance evaluation was performed.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
A "standalone" performance in the context of an algorithm is not applicable here. The computational modeling and simulation for RF-induced heating could be considered a form of "algorithm only" evaluation for a specific physical property of the device, but it is not an AI diagnostic algorithm. It's a scientific modeling approach to predict a physical outcome.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The ground truth for the non-clinical tests and simulations is based on:
- Physical properties and behavior of materials according to established scientific principles.
- Standardized test methods defined by ASTM (e.g., ASTM F2052-21, ASTM F2213-17, ASTM F2119-07, ASTM F2182-19e2).
- FDA-qualified Medical Development Tool (MDDT) for computational modeling, implying its results are considered reliable and accurate.
8. The sample size for the training set
This question is not applicable as there is no mention of a "training set" in the context of artificial intelligence or machine learning. The studies described are non-clinical hardware tests and physics-based simulations, not data-driven AI model training.
9. How the ground truth for the training set was established
This question is not applicable for the same reasons as #8.
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(299 days)
The KLS Martin CranioXpand Spring system is indicated for use in the treatment of cranial conditions such as craniosynostosis and congental deficiencies in which osteotomies and gradual bone distraction are indicated for the infant pediatric subpopulation (29 days of age). The CranioXpand implants are implantable single-use products intended for temporary stabilization of the bony cranial roof during and after surgery. This device is intended to be removed after bone consolidation.
The KLS Martin CranioXpand Spring System consists of implantable spring distractors and supporting instruments intended for temporary stabilization and distraction of the bony cranial roof during and after surgery through distraction osteogenesis. The CranioXpand Springs are offered in various sizes. The spring features include rounded atraumatic contours to ensure optimal embedding in soft tissue with curved ends to ensure the devices can securely anchor in the bone. Two springs are provided as part of the CranioXpand system for anterior and posterior placement on the osteotomies. The springs are removed after adequate bone formation or after the bone consolidation phase is complete. These devices are typically left in the implanted location for 3 - 6 months before explantation. The CranioXpand Instruments are accessories used to facilitate spring size selection, and spring insertion and positioning.
The provided text is a 510(k) Premarket Notification from the FDA, specifically concerning the KLS-Martin L.P. CranioXpand device. This document focuses on demonstrating substantial equivalence to a predicate device, rather than proving the device meets clinical performance acceptance criteria through the types of studies you've queried (e.g., MRMC studies, standalone AI performance, expert ground truth adjudication).
The CranioXpand device is a physical implant (spring system) used for cranial conditions in pediatric patients, not an AI or software-based diagnostic tool. Therefore, the types of studies and acceptance criteria you've asked about, which are common for AI-driven image analysis or diagnostic devices, are not applicable to the information contained within this 510(k) submission.
The "studies" conducted for this device are non-clinical performance bench testing and biocompatibility testing, designed to show that the CranioXpand is as safe and effective as its predicate device.
However, I can extract the information relevant to their acceptance criteria and performance studies for this type of medical device:
Here's a breakdown based on the provided document:
1. Acceptance Criteria and Reported Device Performance
The acceptance criteria for the CranioXpand device, as reported in this 510(k), are focused on bench testing to demonstrate performance equivalence to the predicate device and biocompatibility.
| Acceptance Criteria Category | Specific Criteria | Reported Device Performance |
|---|---|---|
| Biocompatibility | Compliance with ISO 10993-1:2018 for long-term implants in contact with tissue/bone for the springs, and external communicating devices with limited contact for the instruments, covering endpoints such as cytotoxicity, sensitization, irritation, pyrogenicity, carcinogenicity, implantation, acute/subacute/subchronic/chronic toxicity. | The CranioXpand device and accessories were evaluated per FDA guidance "Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management Process" and found to comply with the requirements of ISO 10993-1:2018 thus are considered biocompatible. |
| Spring Testing (Performance Bench Test) | Force measurements during cyclical testing (compressing to 10mm, holding 5s, decompressing, repeated 6 times) must show performance comparable to the predicate device. The exact quantitative criteria for "comparable" are not explicitly stated, but the conclusion is a "Pass." | "A comparison of the performance of the subject and predicate springs via force measurements during cyclical testing was conducted... The acceptance criteria of the test were met, thus demonstrating that the performance of the subject device is substantially equivalent to that of the predicate device." Concluded: Pass |
| Insertion Instruments Testing | Instrument must appropriately open, close, and pick up the spring. Measurements to verify the instrument could compress spring legs sufficiently (<17mm). | "A visual and holding inspection was performed of whether the instrument could appropriately open, close, and pick up the spring. Measurements were conducted to verify that the instrument could compress the spring legs sufficiently (<17mm)." Concluded: Pass |
| Selection Instrument Testing (Static) | Force output via static testing (load applied until 15mm distance between legs, held 5s, unloaded). The specific values of the force output for acceptance are not provided, but the test passed. | "The force output of the selection instrument via static testing was determined by recording the force while first applying a load on the instrument (1.0mm/s until distance between legs is 15mm), holding the position (5 seconds), then unloading the instrument (same speed)." Concluded: Pass |
| Selection Instrument Testing (Dynamic) | Withstand 1000 load cycles at continuous load (load applied at 0.5mm/s to 45mm, held 1s, unloaded, repeated 1000 times). | "Verification of whether the selection instrument could withstand 1000 load cycles at continuous load via dynamic testing was determined by recording the force while repeating the following steps until 1000 cycles are reached: first applying a load on the instrument (45mm at test speed of 0.5mm/s), holding the position, (1 second) then unloading the instrument (same speed)." Concluded: Pass |
2. Sample Size and Data Provenance
- Test Set Sample Size: The document does not specify exact sample sizes for the bench testing beyond implying "samples" of the subject and predicate springs and instruments were tested. For such physical device testing, sample sizes are typically determined by engineering standards and statistical confidence levels relevant to manufacturing variability, rather than patient-based data.
- Data Provenance: The data provenance is from non-clinical laboratory bench testing of the physical devices (springs and instruments). This is not patient data, nor is there any mention of country of origin for such data, as it's likely conducted internally or by contract labs. It is inherently prospective in the sense that the tests are designed and performed to demonstrate specific performance characteristics.
3. Number of Experts and Qualifications for Ground Truth
- Not applicable. This FDA submission is for a physical medical device (implant) and its instruments, not an AI or diagnostic software. Therefore, there is no "ground truth" derived from expert image interpretation or clinical diagnosis in the context of the requested AI-related study types. The "ground truth" for these tests is the physical measurement of force, distance, and visual inspection by testing personnel, adhering to established engineering and quality control standards.
4. Adjudication Method for the Test Set
- Not applicable. As there are no human expert interpretations of data (like images) that require adjudication for ground truth establishment.
5. Multi Reader Multi Case (MRMC) Comparative Effectiveness Study
- No. An MRMC comparative effectiveness study was not conducted as this is a physical implant, not a diagnostic or image-reading AI device. The comparison here is between the subject device's physical performance and the physical performance of a predicate device, as demonstrated through bench testing.
6. Standalone (Algorithm Only) Performance
- Not applicable. There is no algorithm or software for "standalone" performance to be evaluated.
7. Type of Ground Truth Used
- Physical Measurement and Engineering Specifications: The "ground truth" in this context refers to the expected physical properties and performance characteristics of the device (e.g., force specifications, dimensions, functional operation). This is established through engineering design, material specifications, and the performance characteristics of the legally marketed predicate device.
8. Sample Size for the Training Set
- Not applicable. There is no "training set" in the context of this 510(k) submission, as it does not involve machine learning algorithms. Design and manufacturing processes are iteratively refined, but this is distinct from an AI training set.
9. How the Ground Truth for the Training Set Was Established
- Not applicable. As above, no training set for an AI model.
In summary: The provided 510(k) document is for a physical medical implant (CranioXpand) and demonstrates substantial equivalence through biocompatibility testing and engineering bench tests comparing its physical performance to a predicate device. It does not involve AI, image analysis, or clinical studies characteristic of AI-driven diagnostic devices where concepts like MRMC studies, expert ground truth, and training/test sets are relevant.
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(267 days)
The KLS Martin LINOS Wrist System is indicated for use in forearm fractures, osteotomies, and arthrodeses. It is intended for adults, and children (2-12 years) and adolescents (12-21 years) in which growth plates have fused or in which growth plates will not be crossed by fixation.
The KLS Martin LINOS Wrist System consists of metallic plates used in conjunction with bone screws and locking pins intended for the internal fixation, alignment, stabilization, reconstructive osteotomies of the distal radius and/or ulna. Plates are manufactured from Ti-6Al-4V or CP Titanium. Plates are pre-contoured to accommodate patient anatomy and are available in various shapes and dimensions. The system also includes the necessary instruments to facilitate placement of the implants.
This document is a 510(k) summary for the KLS Martin LINOS Wrist System. It outlines the device's characteristics, intended use, and compares it to legally marketed predicate devices to demonstrate substantial equivalence.
Here's an analysis of the provided text in relation to acceptance criteria and study proving device performance:
Crucially, this document does not describe an AI/ML medical device. It describes a traditional Class II orthopedic implant (metallic bone fixation appliance). Therefore, many of the typical acceptance criteria and study aspects for AI/ML devices (like MRMC studies, ground truth establishment for algorithms, training/test set sizes for algorithms, expert adjudication methods for AI performance, etc.) are not applicable to this submission.
The acceptance criteria and study described here are for the mechanical and biocompatibility performance of a physical medical device.
Acceptance Criteria and Device Performance (for a physical orthopedic implant)
Since this is a physical medical device and not an AI/ML algorithm, the "acceptance criteria" table below reflects the types of performance metrics that would be relevant for such a device, and how its performance is typically proven.
| Acceptance Criteria Category | Specific Acceptance Criteria (Generalized for Orthopedic Implants) | Reported Device Performance (from the document) |
|---|---|---|
| Mechanical Performance | Equivalent or superior static and dynamic strength compared to predicate device. | "Comparative head-to-head static and dynamic bench testing was conducted on the subject and predicate...to determine that the subject device has equivalent performance to the primary predicate." "Mechanical test results demonstrate that the KLS Martin LINOS Wrist System's performance is substantially equivalent to the primary predicate device." |
| Screw Performance | Equivalent or superior torsional strength, drive torque, and pullout strength compared to predicate. | "Additionally, comparative screw testing was performed to evaluate torsional strength, drive torque, and pullout strength in accordance with ASTM F543." (Implicitly, the results met the equivalence standard for substantial equivalence). |
| Biocompatibility | Device materials are biocompatible and appropriate for intended use. | "Biological safety risk assessments in compliance with ISO 10993-1:2018 were completed on the subject devices and concluded the devices are biocompatible and appropriate for their intended use." |
| Sterilization | Sterilization process validated to achieve required sterility assurance level. | "The gamma sterilization process for the sterile implants and instrumentation/accessories was validated in accordance with ISO 11137-1:2006 and ISO 11137-2:2012 using the VDmax25 method. The validation was also in accordance with ISO 11737-1:2018 and ISO 11737-2:2019." "The dynamic-air-removal steam sterilization cycle parameters for the non-sterile implants and non-sterile instrumentation/accessories were validated in accordance with ISO 17665-1:2006/(R)2013." |
| Endotoxin Level | Device meets pyrogen limit specifications. | "LAL endotoxin testing was conducted to address the presence of bacterial endotoxins and ensure they meet pyrogen limit specifications in accordance with AAMI ANSI ST72: 2019." |
| Packaging Integrity | Packaging maintains sterility and protects device over shelf life. | "Packaging validations were performed for the PETG blister pack with 1073B Tyvek cover in accordance with ISO 11607-1:2019, ISO 11607-2:2019, and ASTM D4169:2016." |
| Shelf Life | Proven shelf life for sterile components. | "Shelf life for all gamma sterilized components is five (5) years from the date of sterilization." |
Study Information (as applicable to a non-AI/ML medical device 510(k))
Since the provided document is a 510(k) summary for a physical orthopedic implant, not an AI/ML device, many of the requested points below (especially those related to AI/ML specific studies like MRMC or standalone algorithm performance) are not applicable or are addressed by the foundational regulatory framework for traditional medical devices.
-
Sample size used for the test set and the data provenance:
- Test Set (for mechanical testing): The document states "Comparative head-to-head static and dynamic bench testing was conducted on the subject and predicate...". It doesn't specify the exact sample size (N number of implants tested), but standard mechanical testing for medical devices typically involves a statistically robust number of samples to demonstrate equivalence or superiority according to relevant ISO/ASTM standards.
- Data Provenance: The studies are bench tests conducted in a laboratory setting, not on patient data. Thus, "country of origin of the data" or "retrospective/prospective" clinical study design are not relevant in this context. The "data" are mechanical test results.
-
Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not Applicable. For a physical implant device proving mechanical performance, "ground truth" is established by adherence to recognized engineering standards (ASTM, ISO) for material properties, mechanical strength, and biocompatibility. Experts involved would be engineers, material scientists, and toxicologists conducting the tests and interpreting results against these standards, not clinicians establishing "ground truth" on patient images or outcomes.
-
Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not Applicable. This concept is critical for establishing ground truth in clinical data, especially for AI/ML devices where reader variability exists. For mechanical bench testing, results are objective measurements against defined criteria and standards; adjudication of "readings" is not relevant.
-
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:
- Not Applicable. This is a type of study specifically for evaluating the performance of AI/ML diagnostic or prognostic tools when used by human readers (e.g., radiologists interpreting images). The KLS Martin LINOS Wrist System is a surgical implant; it does not involve diagnostic image interpretation or AI assistance for human readers.
- The document explicitly states: "Clinical testing was not necessary for the determination of substantial equivalence." This reinforces that the evaluation was based on non-clinical (bench) testing.
-
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not Applicable. Again, this pertains to an AI/ML algorithm's performance. The device is a physical implant.
-
The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For this physical medical device, "ground truth" for proving substantial equivalence relies on:
- Standardized Mechanical Test Results: Comparing the device's measured mechanical properties (strength, torque, pullout) to those of the predicate device, as defined by ASTM and ISO standards.
- Biocompatibility Standards (ISO 10993-1:2018): Ensuring the materials meet safety criteria for biological interaction.
- Sterilization Standards (ISO 11137, ISO 17665): Demonstrating the effectiveness of the sterilization process.
- Packaging Standards (ISO 11607, ASTM D4169): Verifying package integrity and shelf life.
- For this physical medical device, "ground truth" for proving substantial equivalence relies on:
-
The sample size for the training set:
- Not Applicable. This concept is for AI/ML models. This device does not use a training set.
-
How the ground truth for the training set was established:
- Not Applicable. This concept is for AI/ML models. This device does not use a training set.
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(233 days)
The KLS Martin Level One Rib Fixation System is indicated for use in the stabilization and rigid fixation of rib fractures in the chest wall including reconstructive procedures, trauma, or planned osteotomies in patients 18 years of age or older.
The KLS Martin Level One Rib Fixation System is comprised of PEEK plates and titanium locking screws intended to provide rigid fixation of bone in the thoracic anatomy. The PEEK plates are pre-contoured to accommodate patient anatomy and are offered in plate thicknesses of 2 mm - 3 mm. The PEEK plates are compatible with the Ti-6Al-4V (ASTM F136) 2.3 mm x 7 mm multidirectional locking screws offered in the system. The plates are manufactured from PEEK (ASTM F2026). The system includes the necessary instrumentation
The provided text describes a 510(k) premarket notification for the KLS Martin Level One Rib Fixation System. It focuses on establishing substantial equivalence to predicate devices based on non-clinical performance data and discussions of intended use and technological characteristics.
However, the provided document DOES NOT contain information regarding a study involving AI/algorithm performance for a diagnostic or AI-assisted device. Therefore, I cannot extract the specific details requested in your prompt regarding acceptance criteria and performance studies for an AI device.
The document primarily addresses the substantial equivalence of a physical medical device (rib fixation system) based on mechanical and biological safety testing, rather than a diagnostic or AI-driven system.
Therefore, many of the requested points, such as "table of acceptance criteria and the reported device performance" (for an AI device), "sample size used for the test set and the data provenance," "number of experts used to establish the ground truth," "adjudication method," "MRMC comparative effectiveness study," "standalone performance," "type of ground truth," "sample size for the training set," and "how the ground truth for the training set was established," are not applicable to the content provided.
The non-clinical performance data mentioned refers to:
- Comparative head-to-head bench testing: To determine if the subject device performs equivalently to or better than the primary predicate device in pull-out system testing.
- Comparison to a reference device (Synthes MatrixRIB Fixation System): For pull-out system testing.
- Biological safety risk assessments: In compliance with ISO 10993-1:2018, concluding the devices are biocompatible.
The document explicitly states: "Clinical testing was not necessary for the determination of substantial equivalence." This further confirms that no human-in-the-loop or standalone diagnostic performance studies were conducted or reported in this 510(k) summary.
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(494 days)
KLS Martin Individual Patient Solutions (IPS) is intended as a pre-operative software tool for simulating / evaluating surgical treatment options as a software and image segmentation system for the transfer of imaging information from a medical scanner such as a CT based system. The is processed by the IPS software and the result is an output data file that may then be provided as digital models or used as input in an additive manufacturing portion of the system that produces physical outputs including implants, anatomical models, guides, splints, and case reports for use in maxillofacial, midface, & mandibular surgery.
KLS Martin Individual Patient Solutions (IPS) implant devices are intended for use in the stabilization, fixation, and reconstruction of the maxillofacial / midface and mandibular skeletal regions in children (2 years of age), adolescents (12 years of age - 21 years of age), and adults.
KLS Martin Individual Patient Solutions (IPS) is comprised of a collection of software and associated additive manufacturing equipment intended to produce various outputs to support reconstructive and orthognathic surgeries. The system processes the medical images to produce various patient-specific physical and/or digital output devices which include implants, anatomical models, guides, splints, and case reports.
Patient-specific metallic bone plates are used in conjunction with metallic bone screws for internal fixation of maxillofacial, midface, and mandibular bones. The devices are manufactured based on medical imaging (CT scan) of the patient's anatomy with input from the physician during virtual planning and prior to finalization and production of the device. The physician provides input for model manipulation and interactive feedback by viewing digital models of planned outputs that are modified by trained KLS Martin engineers during the planning session. For each design iteration, verification is performed by virtually fitting the generated output device over a 3D model of the patient's anatomy to ensure its dimensional properties allow an adequate fit.
Implants are provided non-sterile and are manufactured using traditional (subtractive) or additive manufacturing methods from either CP Titanium (ASTM F67) or Ti-6AI-4V (ASTM F136). These patient-specific devices are fixated with previously cleared KLS Martin screws.
Here's a summary of the acceptance criteria and study information for the KLS Martin Individual Patient Solutions device, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for the KLS Martin Individual Patient Solutions device primarily revolve around demonstrating substantial equivalence to predicate devices and ensuring the safety and effectiveness of the device, particularly for the expanded pediatric population and new specifications. The performance is assessed through various non-clinical tests and a review of clinical literature.
| Acceptance Criteria Category | Specific Criteria/Tests | Reported Device Performance |
|---|---|---|
| Material Properties | Biocompatibility (ISO 10993-1) | Cytotoxicity, chemical analysis, sensitization, irritation, and chemical/material characterization leveraged from predicate/reference devices for titanium, synthetic polymers, and acrylic resins. New photopolymer resin for splints passed cytotoxicity, sensitization, irritation, and material-mediated pyrogenicity testing. |
| Mechanical Properties | Bending Resistance and Fatigue Life (ASTM F382) | Determined to be substantially equivalent to K943347 plates (reference device). New worst-case midface, orbit, and mandible plate designs were tested. |
| Sterilization | Sterility Assurance Level (SAL) of 10^-6 (ISO 17665-1:2006) | Validations for titanium devices leveraged from K191028. Validations for synthetic polymers and acrylic resins leveraged from K182789. New photopolymer resin for splints also underwent sterilization validation, with acceptance criteria met. |
| Pyrogenicity | LAL endotoxin testing (AAMI ANSI ST72) | Endotoxin levels below USP allowed limit for medical devices, meeting pyrogen limit specifications. Leveraged from K191028 for titanium devices. |
| Software Performance | Software Verification and Validation | Objective evidence that all software requirements and specifications were correctly and completely implemented, traceable to system requirements. Demonstrated conformity with predefined specifications and acceptance criteria. |
| Clinical Performance (Pediatric Expansion) | Risk mitigation assessments (FDA Guidance "Premarket Assessment of Pediatric Medical Devices") and review of peer-reviewed clinical literature. | Risk assessments addressed various pediatric risk factors. Six clinical studies (patients 18 months to 18 years) were analyzed to support safety and effectiveness in pediatric subpopulations (2 to <12 years, and 12 to 21 years of age), with noted precautions for growth impact and radiation exposure. |
| Substantial Equivalence | Differences in technological characteristics do not raise new or different questions of safety and effectiveness. | Non-clinical performance testing, clinical performance data review, risk analysis, and incorporation of reference devices demonstrated substantial equivalence. |
2. Sample Size Used for the Test Set and Data Provenance
The provided text primarily details non-clinical testing and a review of clinical literature rather than a specific test set for the device's performance in a diagnostic or predictive context.
- Non-clinical testing: The sample sizes for mechanical, biocompatibility, sterilization, and pyrogenicity testing are not explicitly stated in the provided document. These tests are typically conducted on a representative number of device samples according to established standards.
- Clinical Literature Review: The clinical performance data comes from 6 clinical studies that analyzed patients aged 18 months to 18 years. The provenance of this data is retrospective, as it involves a review of published literature findings rather than a new prospective clinical trial conducted by KLS Martin. The specific countries of origin for these studies are not mentioned.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
This information is not applicable in the context of the provided document. The document describes a 510(k) submission for a medical device (surgical planning software and implants), not an AI/ML diagnostic or predictive device that typically requires expert-established ground truth for a test set. The "ground truth" for this device's performance would be the successful outcome of surgical planning and the functional stability of the implants, assessed through non-clinical means and literature review, rather than expert annotation of data.
4. Adjudication Method for the Test Set
This information is not applicable for the reasons stated in point 3.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size
No, an MRMC comparative effectiveness study was not done for this device. The device is a surgical planning tool and implant system, not an AI-assisted diagnostic tool that would typically be evaluated with MRMC studies to assess human reader improvement.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
The device encompasses both software (for pre-operative planning and image segmentation) and physical outputs (implants, models, guides). The software component, KLS Martin Individual Patient Solutions (IPS), is described as a "pre-operative software tool for simulating / evaluating surgical treatment options as a software and image segmentation system." The software itself undergoes "Software Verification and Validation" to ensure it performs as intended based on user requirements and specifications. This suggests the software functionality is evaluated as a standalone component in terms of its technical accuracy and adherence to specifications. However, its effectiveness is intrinsically linked to its use in the context of surgical planning involving human input (physician feedback). Therefore, while the software's functional performance is verified, it is not described as having an 'algorithm only without human-in-the-loop performance' study in the way an AI diagnostic algorithm might be evaluated.
7. The Type of Ground Truth Used
- Non-clinical Performance: The "ground truth" for the non-clinical tests (mechanical, biocompatibility, sterilization, pyrogenicity) is defined by established industry standards and regulatory requirements (e.g., ASTM F382, ISO 10993-1, ISO 17665-1:2006, AAMI ANSI ST72). The device's performance is compared against these standards or against predicate devices that have already met these standards.
- Clinical Performance (Pediatric Expansion): The "ground truth" for supporting the expanded pediatric indications comes from peer-reviewed clinical literature (6 studies cited) that assessed the safety and effectiveness of similar bone plate devices and the subject device's components in pediatric populations, following FDA guidance on "Use of Real-World Evidence."
8. The Sample Size for the Training Set
This information is not provided in the document. Software for medical devices, especially those involving image processing and CAD/CAM, often utilizes pre-existing algorithms and models rather than being trained from scratch on large datasets in the way a deep learning AI might be. If any training was involved, the details are not disclosed here.
9. How the Ground Truth for the Training Set Was Established
This information is not provided in the document. As stated above, it is unclear if a "training set" in the context of machine learning was used. If the software involves image segmentation or manipulation, it likely relies on validated algorithms rather than a dynamically trained model requiring ground truth from human annotations for training.
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(526 days)
The KLS Martin IPS Preprosthetic Implant is a subperiosteal implant composed of titanium intended to construct patient specific prosthetic devices which are surgically implanted into the lower or upper jaw between the periosteum (connective tissue covering the bone) and supporting bony structures. The device is intended to provide support for multi-unit prostheses, such as dentures.
The KLS Martin Individual Patient Solutions (IPS) Preprosthetic system is comprised of patient-specific models and metallic bone plates with integrated pillars used in conjunction with metallic bone screws for internal fixation of the implant to maxillofacial / midface and mandibular bones. The integrated pillars will serve as the base for temporary dentures as well as a permanent prosthesis. The devices are manufactured based on medical imaging (CT scan) of the patient's anatomy with input from the physician during virtual planning and prior to finalization and production of the device. The physician only provides input for model manipulation and interactive feedback by viewing digital models of planned outputs that are modified by trained KLS Martin engineers during the planning session. For each design iteration, verification is performed by virtually fitting the generated implant over a 3D model of the patient's anatomy to ensure its dimensional properties allow an adequate fit.
The KLS Martin IPS Planning System is utilized to plan and design the IPS Preprosthetic implant. The IPS Planning System is a collection of software and associated additive manufacturing (rapid prototyping) equipment intended to provide a variety of outputs to support reconstructive and orthognathic surgeries. The system uses electronic medical images of the patients' anatomy (CT data) with input from the physician, to manipulate original patient images for planning and executing surgery. The system processes the medical images and produces a variety of patient specific physical and/or digital output devices which include anatomical models, implants, and case reports.
Implants are provided non-sterile, range in thickness from 1.2 - 10.0 mm, and are manufactured using additive methods from Ti-6Al-4V (ASTM F136). These patient-specific devices are fixated with previously cleared KLS Martin screws.
Implants have a minimum of two (2) transgingival pillars for the attachment of dental prostheses. The straight pillars (0° to the occlusal plane) have a diameter of 4 mm and are provided at lengths up to 20 mm.
The provided document is a 510(k) summary for the KLS Martin IPS Preprosthetic device and does not contain information about acceptance criteria for an AI/CADe device, nor does it detail a study proving such a device meets those criteria. The device described, the KLS Martin IPS Preprosthetic, is a patient-specific subperiosteal dental implant, not an AI or CADe system.
Therefore, I cannot extract the requested information regarding:
- A table of acceptance criteria and reported device performance for an AI/CADe system.
- Sample size used for the test set and data provenance for an AI/CADe system.
- Number of experts and their qualifications used to establish ground truth for an AI/CADe system.
- Adjudication method for the test set of an AI/CADe system.
- Multi-Reader Multi-Case (MRMC) comparative effectiveness study for an AI/CADe system.
- Standalone performance for an AI/CADe system.
- Type of ground truth used for an AI/CADe system.
- Sample size for and establishment of ground truth for the training set of an AI/CADe system.
The document does mention "Software Verification and Validation" on page 10, stating:
"Software verification and validation was performed on individual software applications that are used in the planning and design of the implant based on the patient's images (CT). Quality and on-site user acceptance testing provide objective evidence that all software requirements and specifications were implemented correctly and completely and are traceable to system requirements. Testing required as a result of risk analysis and impact assessments showed conformity with pre-defined specifications and acceptance criteria. Software documentation demonstrates all appropriate steps have been taken to ensure mitigation of any potential risks and performs as intended based on the user requirements and specifications."
This section indicates that there was software used in the planning and design of the implant, which is based on CT images. This software underwent verification and validation, including "user acceptance testing" and conformity with "pre-defined specifications and acceptance criteria." However, it does not provide the specifics of these acceptance criteria, the study design, or any performance metrics in the format requested for an AI/CADe system. It is a general statement about software V&V, not a study proving the performance of an AI-driven diagnostic or CADe device in a clinical context.
The "Performance Testing - Clinical" section (page 11) discusses the clinical outcomes of the implant device itself (implant loosening, reduced post, exposed/removed screws, infections/abscesses, partial exposure of underlying framework), not the performance of any AI or CADe software used in its design.
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(448 days)
KLS Martin Neuro Rongeurs are manually operated instruments indicated for cutting or biting bone during surgery involving the skull or spinal column in patients two years of age or older.
The KLS Martin Neuro Rongeurs are manual, reusable, stainless-steel instruments. They are provided non-sterile and must be cleaned and sterilized by the end user before use. Validated methods are provided in the instructions for use that accompany each device. The instruments are available coated or uncoated in a variety of styles, with options for a range of cutting angles, shaft lengths and profiles, jaw widths, and handle designs. Additionally, the KLS Martin Neuro Rongeurs can have a push button opening mechanism to allow separation of the long shafts allowing for improved cleaning and sterilization.
This document is a 510(k) Summary for the KLS Martin Neuro Rongeurs, a manual surgical instrument. It describes the device, its intended use, and the testing performed to demonstrate substantial equivalence to predicate devices.
Here's an analysis of the acceptance criteria and study information provided:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state "acceptance criteria" with numerical targets in the conventional sense for medical device performance. Instead, the performance testing section describes the types of tests conducted and uses phrases like "No corrosion detected," "Smooth cuts achieved, pass," and "Comparable to reference device" as outcomes.
Based on the "Performance Testing - Non-clinical" section, here's a table summarizing the tests and results, which serve as the implicit acceptance criteria and reported performance:
| Test Name | Test Description | Implicit Acceptance Criteria | Reported Device Performance |
|---|---|---|---|
| Performance Testing | |||
| Autoclave Test | Test to verify corrosion resistance during autoclaving. | No corrosion detected after autoclaving. | No corrosion detected |
| Boiling Test | Test to verify corrosion resistance of instruments. | No corrosion detected after boiling. | No corrosion detected |
| Copper Sulfate Test | Test to verify corrosion resistance of instruments. | No corrosion detected after Copper Sulfate test. | No corrosion detected |
| Thermal Test | Test to verify thermal resistance of instruments. | No corrosion detected after thermal testing. | No corrosion detected |
| Cut Quality | Compare cut quality. | Achieve smooth cuts comparable to the reference device. | Smooth cuts achieved, pass |
| Comparative Functional Testing | |||
| Spring Force | Compare spring force. | Spring force comparable to the reference device. | Comparable to reference device |
| Cut Force | Compare cut force. | Cut force comparable to the reference device. | Comparable to reference device |
| Push Button Force | Compare push button force. | Push button force comparable to the reference device. | Comparable to reference device |
| Biocompatibility Testing | |||
| Biocompatibility | Evaluated in accordance with ISO 10993. | Meet biocompatibility endpoints (chemical characterization, cytotoxicity, sensitization, etc.). | KLS Martin Neuro Rongeurs are biocompatible. |
| Sterilization Testing | |||
| Steam Sterilization | Validations based on AAMI ANSI ISO 17665-1. | Achieve a sterility assurance level (SAL) of 10⁻⁶ using biological indicator overkill method. | All test method acceptance criteria were met. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: The document does not specify the exact number of KLS Martin Neuro Rongeurs or individual components tested for the non-clinical performance and functional tests. It mentions "Comparative testing was completed versus the reference device," implying a sample of both the subject device and the reference device was used, but quantities are not provided.
- Data Provenance: The document does not explicitly state the country of origin for the data or whether the studies were retrospective or prospective. Given that it's a 510(k) submission for a new device, the performance testing would typically be prospective, conducted by the manufacturer (KLS-Martin L.P. is based in Jacksonville, Florida, USA).
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This type of information is not applicable to this device's performance testing. The KLS Martin Neuro Rongeurs are mechanical surgical instruments. "Ground truth" established by experts (like radiologists reading images) is relevant for diagnostic AI/software devices. For mechanical devices, performance is assessed through objective physical and chemical tests rather than expert interpretation.
4. Adjudication Method for the Test Set
Adjudication methods (e.g., 2+1, 3+1) are typically used in studies involving subjective assessment by multiple readers or experts to resolve discrepancies, particularly in diagnostic contexts. Since the performance testing for these rongeurs involved objective physical and chemical tests, an adjudication method for a "test set" is not applicable.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study was not done. MRMC studies are specific to evaluating diagnostic performance, often with AI assistance compared to human-only performance. This device is a manual surgical instrument, not an AI or diagnostic tool.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study Was Done
No, a standalone study was not done. This question is also typically relevant for AI/software devices that can operate without human intervention. The KLS Martin Neuro Rongeurs are manually operated instruments; they do not have an algorithm or standalone operating mode.
7. The Type of Ground Truth Used
As elaborated in point 3, the concept of "ground truth" as derived from expert consensus, pathology, or outcomes data is not applicable here. The performance data is the ground truth based on objective measurements and observations from the physical and chemical tests (e.g., presence/absence of corrosion, measurement of force, observation of cut quality).
8. The Sample Size for the Training Set
Not applicable. This device is a mechanical instrument, not an AI/software device that requires a "training set" in the machine learning sense.
9. How the Ground Truth for the Training Set Was Established
Not applicable. As stated in point 8, there is no training set for this type of device.
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(132 days)
The KLS Martin Individual Patient Solutions (IPS) Planning System is intended for use as a software system and image segmentation system for the transfer of imaging information from a computerized tomography (CT) medical scan. The input data file is processed by the IPS Planning System and the result is an output data file that may then be provided as digital models or used as input to a rapid prototyping portion of the system that produces physical outputs including anatomical models, guides, and case reports for use in the marking and cutting of cranial bone in cranial surgery. The IPS Planning System is also intended as a pre-operative software tool for simulating / evaluating surgical treatment options. Information provided by the software and device output is not intended to eliminate, replace, or substitute, in whole or in part, the healthcare provider's judgment and analysis of the patient's condition.
The KLS Martin Individual Patient Solutions (IPS) Planning System is a collection of software and associated additive manufacturing (rapid prototyping) equipment intended to provide a variety of outputs to support reconstructive cranial surgeries. The system uses electronic medical images of the patients' anatomy (CT data) with input from the physician, to manipulate original patient images for planning and executing surgery. The system processes the medical images and produces a variety of patient specific physical and/or digital output devices which include anatomical models, guides, and case reports for use in the marking and cutting of cranial bone in cranial surgery.
The provided text is a 510(k) summary for the KLS Martin Individual Patient Solutions (IPS) Planning System. It details the device, its intended use, and comparisons to predicate and reference devices. However, it does not describe specific acceptance criteria and a study dedicated to proving the device meets those criteria in the typical format of a diagnostic AI/ML device submission.
Instead, the document primarily focuses on demonstrating substantial equivalence to a predicate device (K182889) and leveraging existing data from that predicate, as well as two reference devices (K182789 and K190229). The "performance data" sections describe traditional medical device testing (tensile, biocompatibility, sterilization, software V&V) and a simulated design validation testing and human factors and usability testing rather than a clinical study evaluating the accuracy of an AI/ML algorithm's output against a ground truth.
Specifically, there is no mention of:
- Acceptance criteria for an AI/ML model's performance (e.g., sensitivity, specificity, AUC).
- A test set with sample size, data provenance, or ground truth establishment details for AI/ML performance evaluation.
- Expert adjudication methods, MRMC studies, or standalone algorithm performance.
The "Simulated Design Validation Testing" and "Human Factors and Usability Testing" are the closest sections to a performance study for the IPS Planning System, but they are not framed as an AI/ML performance study as requested in the prompt.
Given this, I will extract and synthesize the information available regarding the described testing and attempt to structure it to address your questions, while explicitly noting where the requested information is not present in the provided document.
Acceptance Criteria and Device Performance (as inferred from the document)
The document primarily states that the device passes "all acceptance criteria" for various tests, but the specific numerical acceptance criteria (e.g., minimum tensile strength, maximum endotoxin levels) and reported performance values are generally not explicitly quantified in a table format. The closest to "performance" is the statement that "additively manufactured titanium devices are equivalent or better than titanium devices manufactured using traditional (subtractive) methods."
Since the document doesn't provide a table of acceptance criteria and reported numerical performance for an AI/ML model's accuracy, I will present the acceptance criteria and performance as described for the tests performed:
| Test Category | Acceptance Criteria (as described) | Reported Device Performance (as described) |
|---|---|---|
| Tensile & Bending Testing | Polyamide guides can withstand multiple sterilization cycles without degradation and can maintain 85% of initial tensile strength. Titanium devices must be equivalent or better than those manufactured using traditional methods. | Polyamide guides meet criteria. Additively manufactured titanium devices are equivalent or better than traditionally manufactured ones. |
| Biocompatibility Testing | All biocompatibility endpoints (cytotoxicity, sensitization, irritation, chemical/material characterization, acute systemic, material-mediated pyrogenicity, indirect hemolysis) must be within pre-defined acceptance criteria. | All conducted tests were within pre-defined acceptance criteria, adequately addressing biocompatibility. |
| Sterilization Testing | Sterility Assurance Level (SAL) of 10^-6 for dynamic-air-removal cycle. All test method acceptance criteria must be met. | All test method acceptance criteria were met. |
| Pyrogenicity Testing | Endotoxin levels must be below the USP allowed limit for medical devices that have contact with cerebrospinal fluid (< 2.15 EU/device) and meet pyrogen limit specifications. | Devices contain endotoxin levels below the USP allowed limit (< 2.15 EU/device) and meet pyrogen limit specifications. |
| Software Verification and Validation | All software requirements and specifications are implemented correctly and completely, traceable to system requirements. Conformity with pre-defined specifications and acceptance criteria. Mitigation of potential risks. Performs as intended based on user requirements and specifications. | All appropriate steps have been taken to ensure mitigation of any potential risks and performs as intended based on the user requirements and specifications. |
| Simulated Design Validation Testing | "Passed all acceptance criteria regardless of age or size" for representative cranial case extrapolated to six age ranges. Manufacturable at a high and acceptable level of fidelity, independent of feature size, age of patient, and device size. | Demonstrated that the subject devices passed all acceptance criteria regardless of age or size. Confirms manufacturability at a high and acceptable level of fidelity, independent of feature size, age of patient, and device size. |
| Human Factors and Usability Testing | No potential risks or concerns, outside of those previously raised and mitigated in the IFU, are found. Clinical experts confirm testing and outputs are applicable to real life situations and can be used to effectively execute a planned cranial procedure. | No potential risks or concerns were found (outside of those mitigated in IFU). All clinical experts confirmed the testing and outputs were applicable to real life situations and could be used to effectively execute a planned cranial procedure (pediatric or adult patients). |
Detailed Study Information (Based on available text):
-
Sample size used for the test set and the data provenance:
- Test Set for Simulated Design Validation Testing: A "representative cranial case" was "extrapolated to six (6) distinct age ranges for input data (CT scan) equals output data validation." This implies 6 simulated cases were tested, but no further details on the number of actual CT scans or patients are provided.
- Test Set for Human Factors and Usability Testing: "Eighteen (18) cases were analyzed" (6 distinct age ranges, with outputs sent to 3 clinical experts, meaning 6 (age ranges) x 3 (experts) = 18 cases analyzed in total by the experts).
- Data Provenance: Not specified for the "representative cranial case" in simulated design validation. For human factors, it implicitly used outputs derived from the "six (6) distinct age ranges" based on the system's processing. The document does not specify if the data was retrospective or prospective, or the country of origin.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Simulated Design Validation Testing: Not explicitly stated that experts established ground truth for this test. It seems to be a technical validation against the design specifications.
- Human Factors and Usability Testing: "Three separate clinical experts" were used to review the outputs. Their qualifications are not specified beyond being "clinical experts." Their role was to analyze for potential use problems and make recommendations, and confirm applicability to real-life situations. This is not the establishment of ground truth in the sense of a diagnostic classification.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- No adjudication method is described for either the simulated design validation or human factors/usability testing. The human factors testing involved reviews by multiple experts, but no process for reconciling disagreements or establishing a consensus "ground truth" among them is mentioned; they each provided independent feedback.
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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:
- An MRMC comparative effectiveness study was not conducted according or described in this document. The device is not presented as an AI-assisted diagnostic tool that improves human reader performance in the traditional sense. It's a pre-operative planning system that processes CT data to create physical/digital outputs. The "Human Factors and Usability Testing" involved multiple readers (clinical experts) and multiple cases, but it was for usability assessment rather than a comparative effectiveness study of AI assistance.
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If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- The document describes "Software Verification and Validation" which is a form of standalone testing for the software applications used. It states that "all software requirements and specifications were implemented correctly and completely." However, this is a validation of the software's functionality and adherence to specifications, not a performance study of an AI/ML algorithm's accuracy in a diagnostic context. The system is explicitly described as requiring "trained employees/engineers who utilize the software applications to manipulate data and work with the physician to create the virtual planning session," indicating a human-in-the-loop process for generating the final outputs.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- Simulated Design Validation Testing: The "ground truth" appears to be the "initial input data (.STL)" and the design specifications; the test verifies that "output data (CT scan) equals output data validation" (likely intended to mean input equals output, or input from CT leads to correct output).
- Human Factors and Usability Testing: The "ground truth" is effectively the "expert opinion" of the three clinical experts regarding the usability and applicability of the outputs, rather than a definitive medical diagnosis.
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The sample size for the training set:
- The document describes the KLS Martin IPS Planning System as using "commercially off-the-shelf (COTS) software applications" (Materialise Mimics and Geomagic® Freeform PlusTM) for image segmentation and manipulation. This implies that the core algorithms were pre-existing and not developed by KLS Martin as a novel AI/ML model that would require a distinct training set outlined in this submission. Therefore, no information on a training set size is provided for the device.
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How the ground truth for the training set was established:
- Not applicable, as no training set for a novel AI/ML model by KLS Martin is described. The COTS software validation would have been performed by their respective developers.
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