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510(k) Data Aggregation
(18 days)
OrthoRebirth Co., Ltd.
ReBOSSIS is intended for use in bony voids or gaps that are not intrinsic to the stability of the bony structure. These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone. ReBOSSIS is indicated to be packed gently into bony voids or gaps of the skeletal system (extremities, pelvis, posterolateral spine, and intervertebral disc space). In the extremities and pelvis ReBOSSIS may be used without hydration or hydrated with blood. In the posterolateral spine and intervertebral disc space, ReBOSSIS is to be used hydrated with bone marrow aspirate and mixed with autograft bone. When used in intervertebral body fusion procedures, ReBOSSIS must be used with an intervertebral body fusion device cleared by FDA for use with a bone void filler. The device provides a bone void filler that is resorbed and replaced with host bone during the healing process.
ReBOSSIS is composite material consisting of beta-tricalcium phosphate (B-TCP), siloxanecontaining vaterite (a form of calcium carbonate, CaCO3), and a resorbable scaffold of poly(Llactide-co-glycolide), or PLGa. The electrospinning process used in manufacturing ReBOSSIS results in a glass wool-like (or cotton ball-like) physical form. Due to its physical form, ReBOSSIS is flexible and can easily adapt to and fill in defects in appropriate amounts.
The provided FDA 510(k) clearance document for ReBOSSIS (K240453) does not contain the detailed information necessary to fill out a table of acceptance criteria and the extensive study details commonly associated with AI/ML device evaluations. This document pertains to a resorbable calcium salt bone void filler and primarily focuses on demonstrating substantial equivalence to predicate devices, rather than establishing performance criteria for an AI algorithm.
Therefore, I cannot provide a table of acceptance criteria or populate the detailed study information as requested, because this information is not present in the provided text. The document mainly discusses:
- Device Type: Resorbable Calcium Salt Bone Void Filler (not an AI/ML device).
- Purpose of Submission: To expand the indications for use of the existing ReBOSSIS device (K172573) to include intervertebral disc space.
- Demonstration of Equivalence: Primarily relied on non-clinical testing data and animal testing data from the prior clearance (K172573), supplemented with a clinical rationale.
Specifically, the document states:
- "As the subject device is identical to the previously cleared reference device (K172573), it was determined that the non-clinical testing data and the animal testing data provided in the prior submission is adequate to support the expanded indications proposed in the current submission."
- "Non-clinical testing data and animal testing data, supplemented with a clinical rationale, are referenced to demonstrate the performance of the subject device is substantially equivalent to that of the predicate device."
Given this, the requested information points (especially those related to AI/ML device testing like MRMC studies, standalone algorithm performance, expert consensus for ground truth involving multiple readers, training set details) are irrelevant to the content of this 510(k) summary.
If this were an AI/ML device, the detailed information would be crucial. However, for this specific bone void filler, the focus is on physical, chemical, and biological performance (biocompatibility, resorption, mechanical properties, etc.) typically demonstrated through bench testing and animal studies.
Therefore, I will state that the information requested is not available in the provided text, as the device is not an AI/ML device and the 510(k) is for an expanded indication for a non-AI bone void filler.
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(109 days)
Orthorebirth Co., Ltd.
ReBOSSIS85 is intended for use in bony voids or gaps that are not intrinsic to the stability of the bony structure. These defects may be surgically created osseous defects created from traumatic injury to the bone. ReBOSSIS85 is indicated to be packed gently into bony voids or gaps of the skeletal system (extremities, pelvis, and posterolateral spine). In the extremities and pelvis ReBOSSIS85 may be used without hydrated with blood. In the posterolateral spine ReBOSSIS85 is to be used hydrated with bone marrow aspirate and mixed with autograft bone. The device provides a bone void filler that is resorbed with host bone during the healing process.
ReBOSSIS85 is a synthetic, resorbable bone void filler. It is composite material consisting of (by weight) 40% beta-tricalcium phosphate (B-TCP), 30% siloxane-containing vaterite (a form of calcium carbonate, CaCO3), and 30% poly(L-lactide-co-glycolide). The electrospinning process used in manufacturing ReBOSSIS85 results in a glass wool-like physical form. Due to its physical form, ReBOSSIS85 is flexible and can easily fill defects in appropriate amounts. ReBOSSIS85 is provided sterile for single-patient, single-use.
This document describes a 510(k) premarket notification for ReBOSSIS85, a resorbable calcium salt bone void filler device. The submission aims to demonstrate substantial equivalence to legally marketed predicate devices.
Here's an analysis of the provided information:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly list acceptance criteria in the form of specific performance thresholds for ReBOSSIS85. Instead, the "Performance Data" section details the types of non-clinical tests performed to demonstrate substantial equivalence, and the "Equivalence to Marketed Device" section presents a comparative table between the subject device and predicate devices. The ultimate "acceptance criterion" in a 510(k) context is demonstrating substantial equivalence to a predicate device, meaning it is as safe and effective.
However, we can infer performance areas assessed based on the tests conducted. The key performance comparison is drawn from the in vivo animal study.
Acceptance Criteria (Inferred from study type) | Reported Device Performance (ReBOSSIS85 vs. Predicate K140375) |
---|---|
Radiographic characteristics (bone formation, defect filling etc.) | "performance of the subject ReBOSSIS85 device was equivalent to that of the predicate device K140375" |
Histologic characteristics (tissue reaction, new bone formation, material resorption) | "performance of the subject ReBOSSIS85 device was equivalent to that of the predicate device K140375" |
Histomorphometric characteristics (quantitative analysis of bone formation, material volume) | "performance of the subject ReBOSSIS85 device was equivalent to that of the predicate device K140375" |
Chemical characterization | Detailed analysis of composition (B-TCP, siloxane-containing vaterite, poly(L-lactide-co-glycolide)), Si content, material properties (density, trace elements, residual solvents, surface microstructure, polymer properties). |
Physical characterization | Glass wool-like form, nominal fiber diameter range (3 μm to 150 μm), max diameter (250 μm), approximately 98% porosity (dry). |
Sterilization validation | Methods described in AAMI/ANSI/ISO 11137-1, AAMI/ANSI/ISO 11137-2. |
Shelf life validation (sterile barrier and product) | Methods described in ASTM F1140/F1140M, and ASTM F2096. |
Biocompatibility | Methods described in AAMI/ANSI/ISO 10993-1, -5, -10, -11, -12; Pyrogenicity and bacterial endotoxin (USP 39-NF 34 and ). |
In vitro release kinetics | Release of Si, Ca, and P ions, pH of the solution, material imaging by SEM, polymer weight-average molecular weight by GPC. |
2. Sample size used for the test set and the data provenance
- Test Set Description: The primary test set mentioned for performance evaluation is an in vivo animal study in a rabbit posterolateral fusion model.
- Sample Size: The document does not specify the exact number of animals (sample size) used in this rabbit study.
- Data Provenance: The study was "Animal testing performed to demonstrate substantial equivalence." The document does not specify the country of origin but implies it was conducted by the manufacturer or a contracted lab for regulatory submission. It is by nature prospective observational for the purpose of evaluating the device's performance over time in a biological system.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
The document mentions histological analysis and grading according to AAMI/ANSI/ISO 10993-6 (Annex E). This implies expert evaluation of tissue samples. However, the document does not specify the number of experts or their specific qualifications (e.g., "pathologist with X years of experience") used to establish the ground truth (histologic grades, interpretations of radiographs/micro-CT) for the animal study.
4. Adjudication method for the test set
The document does not specify an adjudication method for the evaluation of the animal study results (radiography, manual palpation, biomechanical testing, micro-CT, histologic analysis, histomorphometric analysis). It only states that "Evaluation endpoints included radiography, manual palpation, non-destructive biomechanical testing, micro-computed tomography (micro-CT) imaging, non-decalcified histologic analysis, and non-decalcified histomorphometric analysis."
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
No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This device is a bone void filler (a physical medical device), not an AI-powered diagnostic or assistive tool for human readers. Therefore, the question about human reader improvement with AI assistance is not applicable.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
No, a standalone algorithm-only performance study was not done. As mentioned, this is a physical medical device, not an algorithm or software.
7. The type of ground truth used
For the animal study:
- Radiographic characteristics: Likely based on expert review of X-ray images.
- Histologic characteristics: Expert interpretation of stained tissue sections by trained histologists/pathologists. Graded according to AAMI/ANSI/ISO 10993-6 (Annex E).
- Histomorphometric analysis: Quantitative measurements derived from histological sections, providing objective metrics about bone formation, material degradation, etc. This is based on direct measurement, not expert consensus in the same way as qualitative grading.
- Micro-computed tomography (micro-CT) imaging: Provides detailed 3D structural information that can be quantitatively analyzed.
- Manual palpation: A subjective assessment.
- Non-destructive biomechanical testing: Objective quantitative measurements of mechanical properties.
Overall, the ground truth for the in-vivo study appears to be a combination of expert interpretation (histology, radiography) and objective measurements (histomorphometry, biomechanics, micro-CT).
8. The sample size for the training set
Not applicable. This document is for a physical medical device (bone void filler), not a machine learning or AI model. Therefore, there is no "training set" in the context of AI.
9. How the ground truth for the training set was established
Not applicable. As this is not an AI/ML device, there is no training set or ground truth in that context. The "ground truth" discussed in point 7 relates to the evaluation of the device's biological performance.
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(114 days)
ORTHOREBIRTH Co., Ltd.
ReBOSSIS85 is intended for use in bony voids or gaps that are not intrinsic to the stability of the bony structure. These defects may be surgically created osseous defects created from traumatic injury to the bone. ReBOSSIS85 is indicated to be packed gently into bony voids or gaps of the skeletal system (extremities and pelvis), and may be used without hydrated with blood. The device provides a bone void filler that is resorbed and replaced with host bone during the healing process.
ReBOSSIS85 is a synthetic, resorbable bone void filler. It is composite material consisting of (by weight) 40% beta-tricalcium phosphate (8-TCP), 30% siloxane-containing vaterite (a form of calcium carbonate, CaCO3), and 30% poly(L-lactide-co-glycolide). The electrospining process used in manufacturing ReBOSSIS85 results in a glass wool-like physical form. Due to its physical form, ReBOSSIS85 is flexible and can easily fill defects in appropriate amounts. ReBOSSIS85 is provided sterile for single-patient, single-use.
Here's a breakdown of the acceptance criteria and the study proving the device meets them, based on the provided text. It's important to note that this document is a 510(k) summary for a medical device (ReBOSSIS85), which focuses on demonstrating "substantial equivalence" to a legally marketed predicate device rather than strictly defining and meeting performance acceptance criteria in the same way a novel device might. Therefore, the "acceptance criteria" here are largely implied by demonstrating comparable performance to the predicate device.
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Safety: Biocompatibility | Passed biocompatibility testing using methods described in AAMI/ANSI/ISO 10993-1, 10993-5, 10993-10, 10993-11, and 10993-12. Pyrogenicity and bacterial endotoxin testing passed using methods described in USP 39-NF 34 and USP 39-NF 34 . |
Effectiveness (Bone Void Filling & Resorption): | |
Comparable radiographic appearance to predicate. | |
Comparable histologic evaluation to predicate. | |
Comparable histomorphometric analysis to predicate. | In a rabbit distal femoral condyle critical-sized defect model, the radiographic, histologic, and histomorphometric performance of ReBOSSIS85 was demonstrated to be equivalent to that of the predicate Actifuse ABX device (K071206). Histology sections were graded according to AAMI/ANSI/ISO 10993-6 (Annex E). |
Material Characteristics: | |
Chemical composition similar to predicate. | |
Physical characteristics similar (or justified differences). | ReBOSSIS85: 40% beta-tricalcium phosphate (β-TCP), 30% siloxane-containing vaterite (SiV), 30% poly(L-lactide-co-glycolide). Approximately 0.7% Si by weight. |
Primary Predicate (Actifuse ABX): Hydroxyapatite (HA), 0.8% Si by weight, resorbable polymer/aqueous gel carrier. | |
Reference Predicate (REBOSSIS): 40% β-TCP, 30% SiV, 30% Poly(L-lactide). 1% Si by weight. |
Physical Form: ReBOSSIS85 and REBOSSIS are "glass wool-like, produced by electrospinning." Actifuse ABX is "Irregularly shaped granules premixed with an aqueous gel carrier." This difference is acknowledged but similarity to the reference predicate is highlighted. |
| Sterility & Shelf Life:
Sterile and stable over time. | Sterilization validation (AAMI/ANSI/ISO 11137-1, 11137-2), sterile barrier shelf life (ASTM F1140/F1140M, ASTM F2096), and product shelf life testing performed. Provided sterile (gamma irradiation). |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Animal Study: Not explicitly stated in the document, but it was tested in "a rabbit distal femoral condyle critical-sized defect model." The number of animals used is not provided.
- Data Provenance: The animal study was conducted to demonstrate substantial equivalence. The country of origin is not specified for the animal study, but the manufacturer (ORTHOREBIRTH Co., Ltd.) is located in Japan. The study is prospective in nature, as it involves implanting the device into animals and observing outcomes over time.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- The document mentions "decalcified histologic evaluation, and histomorphometric analysis. Histology sections also were graded according to AAMI/ANSI/ISO 10993-6 (Annex E)."
- Number of Experts: Not specified.
- Qualifications of Experts: Not specified, but implied to be qualified histologists/pathologists who can grade sections according to ISO standards.
4. Adjudication Method for the Test Set
- The document does not specify an adjudication method like 2+1 or 3+1. Histologic grading "according to AAMI/ANSI/ISO 10993-6 (Annex E)" suggests a standardized evaluation process, but details on how agreement or disagreement among multiple graders (if any were used) was resolved are not provided.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
- No, an MRMC comparative effectiveness study involving human readers with and without AI assistance was not done. This device is a bone void filler, not an imaging analysis AI device.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
- This question is not applicable. The device is a physical bone void filler, not an algorithm or AI. The performance studies evaluate the physical device's biological interaction and efficacy, not an algorithm's output.
7. The Type of Ground Truth Used
- The ground truth for the animal study was established through a combination of:
- Radiographic imaging: To assess bone regeneration.
- Micro-computed tomography (micro-CT) imaging: For detailed 3D assessment of bone architecture and defect filling.
- Decalcified histologic evaluation: Microscopic examination of tissue sections.
- Histomorphometric analysis: Quantitative measurement of tissue components from histological sections.
- These methods collectively provide a definitive biological and structural assessment of the device's performance in vivo.
8. The Sample Size for the Training Set
- This concept is not applicable to a physical medical device like a bone void filler. "Training set" refers to data used to train machine learning algorithms. The development of ReBOSSIS85 would have involved R&D, pre-clinical testing, and optimization, but not in the sense of a "training set" for an algorithm.
9. How the Ground Truth for the Training Set Was Established
- This question is not applicable as there is no "training set" in the context of an algorithm for this physical device. The understanding of appropriate materials and designs for bone void fillers would be based on established medical science, prior device development, and material science research, rather than a labeled training dataset.
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(89 days)
ORTHOREBIRTH CO., LTD.
REBOSSIS is a bone void filler intended for use in bony voids or gaps that are not intrinsic to the stability of the bony structure. These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone. REBOSSIS is indicated to be packed gently into bony voids or gaps of the skeletal system (extremities and pelvis), and may be used without hydration or hydrated with bone marrow aspirate or blood. The device provides a bone void filler that is resorbed and replaced with host bone during the healing process.
REBOSSIS is a synthetic, resorbable bone void filler. It is composite material consisting of (by weight) 40% beta-tricalcium phosphate (B-TCP), 30% siloxane-containing vaterite (a form of calcium carbonate, CaCO3), and 30% poly(L-lactide). The electrospinning process used in manufacturing REBOSSIS results in a glass wool-like physical form. Due to its physical form, REBOSSIS is flexible and can easily fill defects in appropriate amounts.
The provided text is a 510(k) summary for the medical device REBOSSIS, a resorbable calcium salt bone void filler. It details the device's characteristics, intended use, and substantial equivalence to a predicate device. However, it does not include specific acceptance criteria or a study with performance data in the format of acceptance criteria and reported device performance. The document focuses on pre-clinical testing for material characterization and animal studies to demonstrate substantial equivalence, rather than human clinical trials with defined performance endpoints.
Therefore, many of the requested details cannot be extracted directly from the provided text.
Here's a breakdown of what can and cannot be answered based on the provided text:
1. A table of acceptance criteria and the reported device performance
- Cannot be provided. The document does not define explicit acceptance criteria or report device performance against specific targets in a table format. It describes the scope of testing performed (material characterization, biocompatibility, and animal studies) to demonstrate substantial equivalence, not to meet pre-defined performance thresholds for clinical efficacy in humans.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample size for animal testing: The document mentions "Animal testing performed to demonstrate substantial equivalence included determination of radiographic, histologic and histomorphometric characteristics of the subject device and the predicate device in a rabbit distal femoral condyle critical-sized defect model." It further states, "The baseline (time 0) animals included REBOSSIS (dry) and Actifuse Shape (dry) to provide information on the initial amount of material implanted to fill the defects. Autograft bone filled defects (positive control) and empty unfilled defects (negative control) also were evaluated at 6 weeks and 12 weeks."
- Interpretation: While it specifies using a rabbit model and control groups, the exact number of animals per group or the total sample size is not explicitly stated.
- Data provenance: Not explicitly stated but the manufacturer is ORTHOREBIRTH Co., Ltd. from Japan, suggesting the studies could have been conducted there or through contract research organizations globally. The document does not specify whether the data is retrospective or prospective. Given it's a pre-clinical animal study, it would inherently be prospective.
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)
- Not applicable/Not provided. This question pertains to clinical studies often involving human image interpretation or diagnostic outcomes. The provided document describes pre-clinical animal studies involving radiographic, histologic, and histomorphometric evaluations. While expert interpretation would have been involved in these analyses, the document does not specify the number or qualifications of experts for "ground truth" establishment in a clinical context.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable/Not provided. Adjudication methods are typically used in clinical trials involving multiple human readers for diagnostic tasks. This document describes pre-clinical animal studies; therefore, an adjudication method in this context is not relevant and not mentioned.
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
- No. An MRMC study is a clinical study involving human readers and typically an AI component. The provided document explicitly states: "No clinical data were included in this submission." Therefore, no MRMC study or evaluation of human reader improvement with AI assistance was performed or reported.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- No. This question is relevant for AI/algorithm-based devices. REBOSSIS is a physical medical device (bone void filler), not an AI algorithm. Therefore, "standalone algorithm performance" is not applicable.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- For animal studies: The "ground truth" was established through standard scientific methods for pre-clinical animal models:
- Radiographic evaluation: Interpreting X-rays or micro-CT images.
- Histologic evaluation: Microscopic examination of tissue samples.
- Histomorphometric analysis: Quantitative analysis of microscopic tissue structures.
- In these types of studies, experienced veterinary pathologists and radiologists would typically establish findings, which serve as the "ground truth" for the animal model's response to the implant.
8. The sample size for the training set
- Not applicable/Not provided. This question pertains to machine learning algorithms. REBOSSIS is a physical device, not an AI algorithm, so there is no "training set."
9. How the ground truth for the training set was established
- Not applicable/Not provided. As there is no training set for an AI algorithm, this question is not applicable.
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