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510(k) Data Aggregation

    K Number
    K122738
    Date Cleared
    2012-11-07

    (62 days)

    Product Code
    Regulation Number
    888.3040
    Reference & Predicate Devices
    N/A
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Solana Surgical LLC, Gaitway Implant System is intended to treat the hyperpronated foot and stabilize the subtalar joint. It is intended to block forward and medial displacement of the talus, thus blocking excessive pronation and the resulting sequela.

    Device Description

    The Solana Surgical Gaitway Implant is a one-piece device made of Titanium Alloy intended to be implanted in the Sinus Tarsi of the foot. The implant is available in a range of sizes (5) ranging from 6.5 mm to 11.5 mm. The design of the Solana Surgical implant is similar to the predicate devices. No new materials or processes are used in the production of this implant.

    AI/ML Overview

    The provided text is for a 510(k) summary for a medical device called the "Gaitway Implant System," a subtalar arthroereisis implant. The primary goal of a 510(k) submission is to demonstrate substantial equivalence to a legally marketed predicate device, rather than to prove device performance against specific acceptance criteria through a clinical study in the same way a PMA (Pre-Market Approval) study would.

    Therefore, many of the typical acceptance criteria and study details for a software-based or diagnostic device are not applicable to this type of submission. This 510(k) focuses on equivalence in material, geometry, and intended use.

    Here's an analysis based on the provided document:


    1. Table of Acceptance Criteria and Reported Device Performance

    This table is not applicable in the traditional sense of a clinical study with performance metrics for diagnosis or treatment efficacy like sensitivity, specificity, or accuracy. The "acceptance criteria" for a 510(k) for an implantable device like this revolved around demonstrating substantial equivalence to predicate devices in terms of:

    Acceptance Criterion (for Substantial Equivalence)Reported Device Performance (from 510(k))
    Material CompositionIdentical to Memometal and Instratek predicate devices (Titanium Alloy).
    Mechanical Strength Characteristics"Greatly exceeds the mechanical strength characteristics of the Arthrex device" (which is made of PLLA). "Equivalent or greater strength" than predicates.
    Geometry/DesignSimilar to predicate devices; conical shape to fit sinus tarsi. Cannulated.
    Indications for UseIntended to treat hyperpronated foot and stabilize the subtalar joint, blocking forward/medial talus displacement and excessive pronation. This matches the function described for predicate devices.
    Manufacturing/Usage AttributesOne-piece, range of sizes (6.5mm to 11.5mm), single use, surgical implantation longer than 30 days, placed into subtalar sinus tarsi. Consistent with predicate devices.

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

    • Sample Size: Not applicable. This 510(k) is based on a comparison to predicate devices, not a clinical trial with a "test set" of patients in the way a diagnostic device would have a test set of images or cases. The evaluation is primarily bench testing of material properties and design comparison.
    • Data Provenance: Not applicable. There is no patient data involved in demonstrating substantial equivalence in this context. The data comes from engineering specifications and comparisons to existing devices.

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

    • Not applicable. There is no "ground truth" to establish for a test set of patients or data in this type of 510(k) submission. The evaluation is based on engineering principles and regulatory equivalence.

    4. Adjudication Method for the Test Set

    • Not applicable. No test set or human adjudication process is described or required for this type of submission.

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

    • No. An MRMC study is relevant for diagnostic devices where human readers interpret medical images or data. This is an implantable device, and such a study is not part of its 510(k) pathway.

    6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study Was Done

    • No. This is an implantable medical device, not an algorithm or software. Therefore, "standalone performance" in that context is not applicable. The device itself performs its intended function in the body.

    7. The Type of Ground Truth Used

    • Not applicable. For this 510(k), the "ground truth" equivalent would be established engineering and material science principles, and the regulatory understanding of what constitutes a safe and effective implant based on the performance of legally marketed predicate devices. There's no pathology, expert consensus, or outcomes data used to establish ground truth for a test set in this application.

    8. The Sample Size for the Training Set

    • Not applicable. This submission does not involve machine learning or AI algorithms with "training sets."

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

    • Not applicable. As above, no training set is involved.

    Summary of the Study that Proves the Device Meets Acceptance Criteria (Substantial Equivalence):

    The "study" described in the 510(k) summary is a comparative analysis of the Solana Surgical Gaitway Implant System against three legally marketed predicate devices:

    1. Memometal SubFix Arthroereisis Implant (K093820)
    2. Instratek, INC. Sub-Talar Lok, Model 7-11 mm (K080280)
    3. Arthrex Pro Stop Plus (K071456)

    The primary method of demonstrating that the device meets "acceptance criteria" (i.e., is substantially equivalent) involves:

    • Direct Comparison: The applicant explicitly states that "The design of the Solana Surgical implant is similar to the predicate devices."
    • Material Equivalence/Superiority: The device is constructed of Titanium Alloy, which is "identical to the Memometal and Instratek devices." It is also stated that it "greatly exceeds the mechanical strength characteristics of the Arthrex device" (which is PLLA).
    • Geometric Equivalence: All compared devices (Solana Surgical and predicates) are "conical in shape so as to fit into the anatomy of the sinus tarsi" and are "cannulated to accept a guide wire."
    • Indications for Use Equivalence: The indications for use of the Gaitway Implant System are presented, and the summary implies their consistency with the predicate devices: "Each device is placed into the sinus tarsi of the foot, allowing normal subtalar joint motion while blocking excessive pronation."
    • Manufacturing and Usage Parameter Equivalence: All devices are for single use, surgical implantation longer than 30 days, and placed into the subtalar sinus tarsi.

    The conclusion drawn by the applicant, and presumably accepted by the FDA based on the approval letter, is: "Given the similar geometry and equivalent or greater strength, the Solana Surgical device should not introduce new concerns of safety or effectiveness."

    The FDA's letter (K122738) confirms their review and determination that the device is substantially equivalent to legally marketed predicate devices for the stated indications for use. This regulatory determination serves as the "proof" that the device meets the necessary acceptance criteria for market clearance under the 510(k) pathway.

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    K Number
    K120390
    Date Cleared
    2012-04-10

    (63 days)

    Product Code
    Regulation Number
    888.3040
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Solana Surgical LLC, Sola Fix Twist Screw Implant System is intended to provide fixation for fracture, fusion, osteotomy or reconstruction of the bones of the hand and foot.

    Device Description

    The Solana Surgical Implant is a one-piece device made of Titanium Alloy intended to be used as a screw for bone fixation, fusion, osteotomy or reconstruction of the hand and foot. The implant is available in a range of sizes (6) including 2.0mm diameter and length range of 11-16mm. The screw driving portion of the screw is intended to separate from the screw head once the screw seats to the bone.

    AI/ML Overview

    This document is a 510(k) summary for a medical device called the "Sola Fix Twist Screw Implant System" by Solana Surgical, LLC. The summary focuses on establishing substantial equivalence to a predicate device, rather than proving performance against specific acceptance criteria for a novel AI/software product. Therefore, much of the requested information regarding AI device studies (like sample sizes for test/training sets, expert consensus, MRMC studies, etc.) is not applicable.

    Here's an analysis based on the provided text, adapted to the context of a mechanical device submission:

    Acceptance Criteria and Device Performance

    Since this is a submission for a mechanical implant, the "acceptance criteria" are typically defined by recognized standards for mechanical testing and comparison to an already marketed predicate device. The "device performance" is demonstrated by meeting these standards and showing comparable characteristics.

    Acceptance CriterionReported Device PerformanceComments
    Mechanical Testing per ASTM F543Mechanical testing was performed according to ASTM F543.This standard likely specifies various mechanical properties (e.g., tensile strength, fatigue life, torsional strength) that the screw must meet. The document states it was performed, implying successful adherence to the standard's requirements to demonstrate safety and efficacy.
    Engineering/Dimensional Comparison to Predicate DeviceAn engineering/dimensional comparison to the predicate device was performed.This implies that the Sola Fix Twist Screw Implant System is dimensionally and structurally similar enough to the predicate device (Charlotte Snap-Off Screw, K050819) to justify "substantial equivalence."
    Material CompositionMade of Titanium Alloy; No new materials.The device uses industry-standard Titanium Alloy, the same or similar to the predicate, ensuring biocompatibility and established mechanical properties.
    Intended Use"Intended to provide fixation for fracture, fusion, osteotomy or reconstruction of the bones of the hand and foot."The intended use statement is identical or highly similar to the predicate device, a key aspect of demonstrating substantial equivalence.
    Device ConfigurationOne-piece device; Screw driving portion separates from screw head; Available in a range of sizes (2.0mm diameter, 11-16mm length).These characteristics were compared to the predicate to ensure similar functionality and application.

    Important Note: The document explicitly states: "Based on the evaluations performed, the design and indications of the Solana Surgical screw are substantially equivalent to the predicates identified in the 510(k) submission. No new materials or processes are used in the development of this implant." This is the overarching "performance" claim for a 510(k) for a mechanical device – demonstrating substantial equivalence, not novel performance metrics.

    Study Information (as applicable to a mechanical device)

    Given this is a 510(k) for a mechanical bone fixation screw, the concepts of "test set," "training set," "experts," "adjudication," "MRMC studies," and "standalone performance" as they relate to AI/software are not applicable. The "study" here refers to the mechanical and comparative analyses performed.

    1. Sample size used for the test set and the data provenance:

      • Test Set Sample Size: Not applicable in the context of AI/software. For mechanical testing, the "sample size" would refer to the number of screws subjected to testing (e.g., N=5 or N=10 per test). This specific number is not provided in the summary but would be detailed in the full 510(k) submission.
      • Data Provenance: Not applicable in the AI/software sense. The data comes from in vitro mechanical testing performed in a lab setting, likely by or for Solana Surgical, LLC.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for mechanical devices is established through adherence to engineering standards (e.g., defining load limits, dimensions) and comparison to a legally marketed predicate. There isn't an "expert consensus" on an image or clinical case.

    3. Adjudication method for the test set: Not applicable. Adjudication is not relevant for compliance with mechanical engineering standards.

    4. 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 an AI-powered device.

    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is not an AI algorithm. Its performance is inherent in its mechanical properties.

    6. The type of ground truth used: For this type of device, the "ground truth" is adherence to established mechanical engineering standards (ASTM F543) and factual engineering/dimensional data for comparison to the predicate. The "truth" is whether the device meets the specified mechanical properties and is sufficiently similar to an already approved device.

    7. The sample size for the training set: Not applicable. There is no training set for a mechanical device.

    8. How the ground truth for the training set was established: Not applicable.

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    K Number
    K120029
    Date Cleared
    2012-02-06

    (33 days)

    Product Code
    Regulation Number
    888.3730
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Solana Surgical LLC, Hemi Phalangeal Implant System is intended for use as a hemi-arthroplasty implant for the metatarsophalangeal joint, for the treatment of degenerative and post-traumatic arthritis, hallux valgus, hallux rigidus, and an unstable or painful metatarsophalangeal (MTP) joint.

    The device is intended for single use to be used with bone cement or press fit without bone cement.

    Device Description

    The Solana Surgical Implant is a one-piece device made of Cobalt Chromium (with titanium plasma spray coated stem) intended to replace the articulating surface of the phalangeal bone at the metatarsalphalangeal (MTP) joint. The implant is available in a range of sizes (3) to match the geometry of the metatarsal phalangeal joint. Design features include an articulating surface and a stem which extends distally in the intramedullary canal of the proximal phalanx. The design of the Solana Surgical implant is similar to the predicate devices. No new materials or processes are used in the development of this implant.

    AI/ML Overview

    The provided text describes a medical device, the Solana Surgical Hemi Phalangeal Implant System, and its substantial equivalence to predicate devices, but it does not contain any information regarding acceptance criteria, device performance, or a study proving it meets acceptance criteria.

    The document is a 510(k) summary and an FDA clearance letter, which focuses on establishing substantial equivalence based on similarities in:

    • Intended use: Hemi-arthroplasty implant for the metatarsophalangeal joint to treat degenerative and post-traumatic arthritis, hallux valgus, hallux rigidus, and unstable/painful MTP joint.
    • Device description: One-piece device made of Cobalt Chromium (with titanium plasma spray coated stem).
    • Materials: Industry standard materials, no new materials.
    • Design features: Articulating surface and a stem extending distally into the intramedullary canal.
    • Sizes: Available in a range of 3 sizes.
    • Usage: Single use, with or without bone cement.

    Therefore, I cannot provide the requested table or details about a study demonstrating acceptance criteria, as this information is not present in the provided text. The document is about regulatory clearance for a medical implant, not a performance study of an AI/software device.

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    K Number
    K113752
    Date Cleared
    2012-02-06

    (47 days)

    Product Code
    Regulation Number
    888.3730
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Solana Surgical LLC, Metatarsal Decompression Implant is intended for use as a hemi-arthroplasty implant for the first metatarsophalangeal joint, for the treatment of degenerative and post-traumatic arthritis, hallux valgus, hallux rigidus, and an unstable or painful metatarsophalangeal (MTP) joint.

    The device is intended for single use to be used with bone cement or press fit without bone cement.

    Device Description

    The Solana Surgical Implant is a one-piece device made of Cobalt Chromium (with titanium plasma spray coated stem) or Titanium, intended to replace the articulating surface of the metatarsal bone at the metatarsalphalangeal (MTP) joint. The implant is available in a range of sizes to match the geometry of the metatarsal phalangeal joint. Design features include an articulating surface and a stem which extends proximally in the intramedullary canal of the distal metatarsal. The design of the Solana Surgical implant is similar to the predicate devices. No new materials or processes are used in the development of this implant.

    AI/ML Overview

    The provided text is a 510(k) summary for the Solana Surgical Metatarsal Decompression Implant. It details the device's description, indications for use, and a comparison to predicate devices, ultimately concluding substantial equivalence. However, it does not contain any information about acceptance criteria, device performance studies, sample sizes, expert qualifications, adjudication methods, MRMC studies, standalone performance, or training set details.

    Therefore, I cannot fulfill your request for that specific information based on the provided text.

    The document primarily focuses on establishing substantial equivalence to previously cleared devices rather than providing detailed clinical or performance study results against predefined acceptance criteria.

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    K Number
    K090127
    Date Cleared
    2009-05-01

    (100 days)

    Product Code
    Regulation Number
    888.3730
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Solana Surgical LLC, Metatarsal Decompression Implant is intended for use as a hemi-arthroplasty implant for the first metatarsophalangeal joint, for the treatment of degenerative and post-traumatic arthritis, hallux valgus, hallux rigidus, and an unstable or painful metatarsophalangeal (MTP) joint.

    The device is intended for single use to be used with bone cement.

    Device Description

    The Solana Surgical Implant is a one-piece device made of Cobalt Chromium, intended to replace the articulating surface of the first metatarsal at the metatarsalphalangeal (MTP) joint. The implant is available in a range of sizes to match the geometry of the metatarsal head. Design features include an articulating surface and a stem which extends proximally in the intramedullary canal of the metatarsal. The design of the Solana Surgical implant is similar to the predicate devices. No new materials or processes are used in the development of this implant.

    AI/ML Overview

    This K090127 document is a 510(k) summary for a medical device called the "Metatarsal Decompression Implant" by Solana Surgical, LLC. It is a premarket notification to the FDA to demonstrate substantial equivalence to previously marketed predicate devices.

    Based on the provided text, there is no information regarding acceptance criteria or a study that proves the device meets specific performance criteria in the way you've outlined for an AI or diagnostic device. This document is for a physical implant, not a software or AI device.

    Therefore, I cannot provide the requested information in the format of a table for acceptance criteria and reported device performance, nor can I answer questions about sample sizes, ground truth establishment, expert qualifications, adjudication methods, MRMC studies, standalone performance, or training set details. These concepts are not applicable to the content of this 510(k) submission.

    The document primarily focuses on:

    • Device Description: A one-piece Cobalt Chromium implant for the first metatarsal at the MTP joint.
    • Indications for Use: Hemi-arthroplasty for degenerative/post-traumatic arthritis, hallux valgus, hallux rigidus, and unstable/painful MTP joint. Single-use with bone cement.
    • Comparison to Predicate Device: Emphasizes similarities in intended use, materials, design characteristics, and standard materials used, leading to an assertion of substantial equivalence.
    • Regulatory Information: Device classification, product code, and predicate devices.

    The FDA's eventual letter confirms substantial equivalence, which is a regulatory determination based on comparing the new device to existing legally marketed devices, rather than a performance study against specific acceptance criteria for a new type of functionality.

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