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510(k) Data Aggregation

    K Number
    K151004
    Date Cleared
    2015-11-17

    (216 days)

    Product Code
    Regulation Number
    888.3040
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    SBM SCIENCES FOR BIO MATERIALS

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The PULLUP® device is designed to be used as juxtacortical fixation for ACL reconstruction.

    Device Description

    The PULLUP® Adjustable Juxtacortical Fixation Device consists of an adjustable nonabsorbable braided loop and titanium button. The system is preloaded with traction threads. The PULLUP® Adjustable Juxtacortical Fixation Device is available in 2 versions: -PULLUP® for cortical tunnels having a diameter of 4.5 mm - PULLUP®XL for cortical tunnels having a diameter between 5 and 10 mm - The implant is supplied sterile, ready to use.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for a medical device called the PULLUP® Adjustable Juxtacortical Fixation Device. This type of regulatory submission focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than conducting a full clinical trial to establish safety and effectiveness from scratch.

    Therefore, the document does not contain the detailed information on acceptance criteria and a study proving a device meets those criteria in the context of an AI/ML medical device, clinical trial, or diagnostic test. Instead, it demonstrates the device's performance through non-clinical performance testing to establish equivalence to predicate devices.

    Here's an analysis based on the information available in the document, framed against your requested categories, with explanations for what is not present:

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

    The document does not provide a formal table of acceptance criteria with corresponding performance metrics in the way one would expect for an AI/ML device or a clinical outcome study. Instead, it makes a general statement about non-clinical performance testing:

    Acceptance Criteria (Implied)Reported Device Performance
    Device is as safe as predicate devices"Non clinical performance testing demonstrated that PULLUP® device is as safe, as effective, and performs at least as safely and effectively as its predicate devices."
    Device is as effective as predicate devices"Non clinical performance testing demonstrated that PULLUP® device is as safe, as effective, and performs at least as safely and effectively as its predicate devices."
    Device performs at least as safely and effectively as predicate devices"Non clinical performance testing demonstrated that PULLUP® device is as safe, as effective, and performs at least as safely and effectively as its predicate devices." and "Verification and validation tests demonstrate that the PULLUP® device is as safe, as effective, and performs as safely and effectively as its predicate device."

    The "non-clinical performance testing" would typically involve bench testing for mechanical properties (e.g., strength, fatigue, pull-out force) designed to show equivalence to the predicate devices. The specific metrics, thresholds, and results of these tests are not provided in this summary.

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

    This information is not applicable and therefore not provided. The document states, "No clinical data has been presented." The performance testing mentioned is non-clinical (i.e., bench testing, not human patient data).

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

    This information is not applicable. Since no clinical data or human-interpreted data is referenced, there's no ground truth established by experts in this context.

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

    This information is not applicable, as there is no human interpretation of data requiring 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 information is not applicable. The device is a mechanical fixation device, not an AI/ML diagnostic or assistive tool.

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

    This information is not applicable. The device is a mechanical fixation device; there is no algorithm involved.

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

    For the non-clinical performance testing, the "ground truth" would be established by validated engineering test methods and relevant ASTM/ISO standards for mechanical testing of orthopedic implants. This often involves measuring parameters like tensile strength, cyclic loading, and pull-out strength, comparing the results of the new device against the known performance of the predicate devices under identical test conditions. Specific details are not disclosed in this summary.

    8. The sample size for the training set

    This information is not applicable. There is no AI/ML algorithm requiring a training set.

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

    This information is not applicable. There is no AI/ML algorithm requiring a training set.

    In summary: The provided 510(k) summary is for a physical medical device. It relies on non-clinical performance testing to demonstrate substantial equivalence to predicate devices (Arthrex TightRope RT and Biomet ToggleLoc System) in terms of safety and effectiveness. It explicitly states that "No clinical data has been presented." Therefore, the detailed information requested regarding AI/ML device studies, human readers, ground truth establishment by experts, and clinical trial specifics (like sample size, data provenance, adjudication) is not relevant or available in this document.

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    K Number
    K130953
    Date Cleared
    2013-07-15

    (101 days)

    Product Code
    Regulation Number
    888.3045
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    SBM SCIENCES FOR BIO MATERIALS

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    BIOSORB Resorbable Bone Void Filler is a resorbable calclum salt bone void filler intended to fill bony voids or gaps of the skeletal system (i.e. the extremities, posterolateral spine and pelvis,) caused by trauma or surgery, that are not intrinsic to the stability of the bony structure. BIOSORB Resorbable BoneVoid Filler does not possess sufficient mechanical strength to support reduction of a defect prior to soft and hard tissue ingrowth. Rigid fixation techniques are recommended as needed to assure stabilization of the defect in all plans.

    In addition, when used with appropriate opening osteotomy system devices, plates and screws, BIOSORB Resorbable Bone Void Filler Is Intended to be used as a bone void filler in tiblal osteotomies.

    Device Description

    BIOSORB bone void filler (K021963 and K071155) is an osseo-conductive macroporous implant made of synthetic beta tri Calcium Phosphate (βΤCP) indicated for Bone Void Filling.

    BIOSORB bone void filler presents a multidirectional interconnected porosity structure, similar to that of the human cancellous bone. BIOSORB bone void filler implant slowly resorbs during the remodeling and bone defect repair process and is progressively replaced with bone and soft tissues.

    To better fit the surgeon's needs and surgical preferences and patient's anatomy the full range of BIOSORB RESORBABLE BONE VOID FILLER will comprise:

    • 9 shapes: stick, granule, cube, block (6 shapes) o
    • 3 material specifications: BIOSORB 30, BIOSORB 45 and BIOSORB 70 o
    • 3 packaging: box, vial, syringe 0

    The design modifications of the new NEOTIS set of wedges with respect to OTIS set of wedges include a sharper anterior area and a wider posterior area more fitting the natural tibia anatomy. 3 letters are printed to help the surgeon with the wedge orientation: A stands for Anterior, M stands for Medial and P for Posterior.

    There are 50 NEOTIS parts instead of 10 OTIS parts, so that the range is increased.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the BIOSORB Resorbable Bone Void Filler, based on the provided document:

    1. Acceptance Criteria and Reported Device Performance

    Acceptance CriteriaReported Device Performance
    Conforms to Class II Special Controls Guidance: "Resorbable Calcium Salt Bone Void Filler Device; Guidance for Industry and FDA" (established for 21 CFR 888.3045).The device "conforms to Class II Special Controls Guidance: Resorbable Calcium Salt Bone Void Filler Device; Guidance for Industry and FDA" established for Resorbable calcium salt bone void filler (21 CFR 888.3045).
    Offers enhanced anatomical fitting for HTO (High Tibial Osteotomy) opening filling compared to previous designs. (Implied acceptance criteria: The design modification should reduce the risk of inadequate filling and not generate new risks, demonstrating equivalent or better safety and effectiveness compared to the predicate.)The new implant design offers "an enhanced anatomical fitting for HTO opening filling as verified by surgeons through cadaveric labs (RD837 - enclosed in Appendix 1)". The design modification reduces the risk of inadequate filling and does not generate new risks. The device is as safe, as effective and performs as well as or better than the predicate BIOSORB RESORBABLE BONE VOID FILLER.

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size for Test Set: Not explicitly stated. The document mentions "cadaveric labs" but does not specify the number of cadavers or individual tests performed.
    • Data Provenance: The cadaveric labs likely involved human cadavers. The country of origin is not specified, but the submitter is based in France. The study was prospective in the sense that new tests were conducted for this submission.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications

    • Number of Experts: Not explicitly stated, however, the document refers to validation "by surgeons." This implies multiple surgeons were involved.
    • Qualifications of Experts: "Surgeons" are the explicitly stated experts. No further details on their specific qualifications (e.g., years of experience, subspecialty) are provided.

    4. Adjudication Method for the Test Set

    • Adjudication Method: Not specified. The document only states that the enhanced anatomical fitting was "verified by surgeons." It doesn't detail how consensus was reached or how discrepancies (if any) were handled among the surgeons.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    • MRMC Study: No, an MRMC comparative effectiveness study was not done. The study focused on verifying the anatomical fitting of the device through cadaveric labs, not on comparing human reader performance with and without AI.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    • Standalone Performance: No, this is not applicable. The device is a physical bone void filler, not an AI algorithm. The performance evaluation involved physical assessment by surgeons in cadaveric labs.

    7. The Type of Ground Truth Used

    • Type of Ground Truth: The ground truth for the device's enhanced anatomical fitting was based on expert assessment/consensus by surgeons through cadaveric labs.

    8. The Sample Size for the Training Set

    • Sample Size for Training Set: Not applicable. This is a physical medical device, not an AI/ML algorithm that requires a training set. The development of the device design would involve engineering and material science principles, possibly with iterative design and testing, but not a "training set" in the context of machine learning.

    9. How the Ground Truth for the Training Set Was Established

    • Ground Truth for Training Set: Not applicable, as this is not an AI/ML device. The design evolution of the BIOSORB Resorbable Bone Void Filler was likely informed by clinical experience with previous versions (K021963 and K071155) and anatomical considerations.
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    K Number
    K122228
    Date Cleared
    2012-10-03

    (69 days)

    Product Code
    Regulation Number
    888.3030
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    SBM SCIENCES FOR BIO MATERIALS

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    LIGAFIX® / ComposiTCP® is a cannulated, sterile, single-use, resorbable interference bone screw made of a mixture of tri calcium phosphate (beta-TCP) and Poly Lactic Acid (PLA) designed for the interference fixation of grafts in anterior cruciate ligament reconstruction.

    Device Description

    LIGAFIX / ComposiTCP range of products consists of resorbable cannulated screws available in several models designed for the interference fixation of grafts in anterior cruciate ligament reconstruction. LIGAFIX / ComposiTCP interference bone screw is made of a ceramic (beta-TCP) / polymer (Poly Lactic Acid -PLA) composite. LIGAFIX / ComposiTCP interference screw is available in several sizes and in two beta-TCP/ PLA ratios 60/40 (LIGAFIX 60/ ComposiTCP 60) and 30/70 (LIGAFIX 30/ ComposiTCP 30). LIGAFIX / ComposiTCP interference bone screws are supplied sterile and individually packaged in double heat sealed pouches. The purpose of this 510(k) was to address modifications to the head of certain screw configurations, along with modifications to the cannula to allow use with 1.1mm guide wire. The subject system offers screws in diameters ranging from 7 mm to 12 mm with lengths ranging from 20 mm to 35 mm.

    AI/ML Overview

    This is a medical device 510(k) submission for a resorbable interference screw, not an AI/ML device. Therefore, many of the requested categories (such as sample size for test set, number of experts, adjudication method, MRMC study, standalone performance, training set size, and ground truth for training set) are not applicable.

    Here's an analysis based on the provided text, focusing on the available information for a traditional medical device:

    Acceptance Criteria and Device Performance for LIGAFIX Interference Screw

    The device, LIGAFIX Interference Screw, is a traditional medical device and not an AI/ML algorithm. Therefore, the acceptance criteria and study data are presented in terms of mechanical and biocompatibility performance rather than metrics typically associated with AI/ML (e.g., AUC, sensitivity, specificity, F1-score).

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySpecific Criteria (Implicit/Explicit)Reported Device Performance
    BiocompatibilityDevice materials (beta-TCP and PLA) must be safe for implantation and not cause adverse biological reactions."Mechanical tests and dimensional analysis confirmed that LIGAFIX / ComposiTCP screws are biocompatible..." (This indicates the device passed relevant biocompatibility assessments, likely according to ISO 10993 standards, although specific tests are not detailed in this summary.)
    Mechanical StrengthThe screw must possess sufficient mechanical strength to provide sustained fixation of the graft in anterior cruciate ligament reconstruction."Mechanical tests and dimensional analysis confirmed that LIGAFIX / ComposiTCP screws are... presents the requisite strength to provide sustained fixation of the graft." (Specific strength values or comparative data to predicates are not provided in this summary, but the statement implies successful performance against a defined standard or in comparison to predicate devices.)
    Dimensional ConformanceThe modified head and cannula of certain screw configurations must conform to specified dimensions to allow use with a 1.1mm guide wire."Mechanica tests and dimensional analysis confirmed that LIGAFIX / ComposiTCP screws are... presents the requisite strength to provide sustained fixation of the graft." (The summary explicitly mentions "modifications to the head of certain screw configurations, along with modifications to the cannula to allow use with 1.1mm guide wire." The dimensional analysis would have confirmed these changes met the design specifications.)
    Substantial EquivalenceThe modified device must be substantially equivalent to predicate devices in terms of intended use, material, design, mechanical properties, and function."The additional LIGAFIX / ComposiTCP Interference screws are substantially equivalent to their predicate devices LIGAFIX / ComposiTCP Interference screw (K050407, K061262, K070507 and K090994) in terms of intended use, material, design, mechanical properties and function."

    2. Sample Size Used for the Test Set and Data Provenance

    • Test Set Sample Size: Not explicitly stated. For mechanical and biocompatibility testing of traditional medical devices, sample sizes are typically determined by regulatory standards (e.g., ISO, ASTM) and statistical considerations for material property testing, rather than a clinical "test set" in the AI/ML sense. The text mentions "mechanical tests and dimensional analysis," which would involve testing a specific number of manufactured units.
    • Data Provenance: Not specified, but generally, such testing is conducted in a controlled laboratory environment by the manufacturer or a contracted testing facility. The manufacturer is "SCIENCE FOR BIOMATERIALS" located in France.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications

    • Not Applicable. This is a physical medical device. "Ground truth" in the context of AI/ML (e.g., expert consensus on image labels) is not relevant here. Device performance is assessed through objective physical and chemical tests based on established standards.

    4. Adjudication Method for the Test Set

    • Not Applicable. As this is not an AI/ML device, there's no "adjudication method" in the sense of resolving discrepancies between expert opinions on a dataset. Performance is determined by compliance with engineering specifications and regulatory standards.

    5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done

    • Not Applicable. MRMC studies are specific to evaluating the diagnostic performance of imaging devices or AI algorithms involving human readers. This device is an implantable screw.

    6. If a Standalone Performance (i.e., algorithm only without human-in-the-loop performance) Was Done

    • Partially Applicable (in a different context). The "standalone performance" of the device refers to its physical and biological performance (biocompatibility, mechanical strength) as an implantable object, independent of a human-in-the-loop diagnostic process. The text states: "Mechanical tests and dimensional analysis confirmed that LIGAFIX / ComposiTCP screws are biocompatible and presents the requisite strength to provide sustained fixation of the graft." This represents the device's inherent performance characteristics.

    7. The Type of Ground Truth Used

    • For physical and chemical properties: Objective Measurement/Standard Compliance. Ground truth is established by physical measurements (e.g., dimensions, load-to-failure), chemical analysis for material composition, and biological assays for biocompatibility, all compared against pre-defined engineering specifications and relevant regulatory standards (e.g., ISO standards for medical devices, ASTM standards for materials testing).
    • For substantial equivalence: Comparison against the characteristics of the legally marketed predicate devices.

    8. The Sample Size for the Training Set

    • Not Applicable. There is no "training set" as this is not an AI/ML device that learns from data.

    9. How the Ground Truth for the Training Set Was Established

    • Not Applicable. There is no "training set" for this type of medical device.
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