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510(k) Data Aggregation
(518 days)
ALLOFUSE GEL AND PUTTY
AlloFuse is indicated for orthopedic applications as filler for gaps or voids that are not intrinsic to the stability of the bony structure. AlloFuse® is indicated to be packed gently into bony gaps in the skeletal system as a bone graft extender (extremities, spine, and pelvis) and as bony void filler of the extremities and pelvis. These defects may be surgically created or from the result of traumatic injury to the bone.
AlloFuse is derived from selected donated human bone tissue that has been processed into particles. The bone particles are subsequently demineralized using a hydrochloric acid process. The demineralized bone matrix (DBM) is combined with an inert reverse phase carrier and formulated into a gel or putty-like consistency.
The carrier is a solution of polyethylene oxide polypropylene oxide block copolymer dissolved in water exhibiting reverse phase characteristics (i.e. an increase in viscosity as temperature increases).
Here's an analysis of the provided text, outlining the acceptance criteria and the studies mentioned for the AlloFuse Gel and Putty device:
Executive Summary:
The provided document describes the 510(k) submission for AlloFuse Gel and Putty, which claims substantial equivalence to the predicate device, DynaGraft® II. The primary "acceptance criteria" is demonstrating substantial equivalence due to the proposed device being the same in design, materials, and function as the predicate device. This is supported by:
- Viral Inactivation Validation: Testing of the DBM processing method to ensure viral inactivation.
- Osteoinductive Potential: An in vivo assay in athymic rats confirms osteoinductive potential for every lot.
- Product Performance Testing: Reference to studies on the predicate device (DynaGraft® II) in rabbit and sheep models (radiographic and histological) and human clinical studies for spinal fusions.
1. Table of Acceptance Criteria and Reported Device Performance
It's important to note that the document does not explicitly present a table of numerical "acceptance criteria" and direct performance metrics for the AlloFuse device itself in the way one might see for a diagnostic AI model. Instead, the acceptance is based on demonstrating substantial equivalence to a predicate device. The performance data presented primarily pertains to the predicate device or the processing methods.
Acceptance Criterion (Implicit) | Reported Device Performance |
---|---|
Premarket Requirement: Demonstrated Substantial Equivalence to Predicate Device (DynaGraft® II) | The proposed device is stated to be "the same device in design, materials of construction and function" as the previously cleared DynaGraft® II. AlloSource also holds an exclusive license to manufacture the predicate device. This is the primary claim for substantial equivalence. |
Material Safety (Viral Inactivation) | The DBM processing method (for AlloFuse) was evaluated for its viral inactivation potential, demonstrating "significant viral inactivation potential for a wide range of potential human viruses" using a panel of viruses. |
Biological Activity (Osteoinductive Potential) | AlloFuse has shown "osteoinductive potential in athymic rats." "Every lot of final product is tested via an in vivo assay to ensure osteoinductive potential." |
Clinical Performance / Efficacy | Not directly tested on AlloFuse in human trials for this submission. Instead, the submission relies on: |
- Product Performance Testing (Predicate): DBM in RPM carrier (DynaGraft® II formulation) evaluated in rabbit and sheep models by radiographic and histological methods.
- Clinical Studies (Predicate): Clinical studies using DynaGraft® II DBM Putty and Gel for spinal fusions "demonstrating acceptable outcomes." |
| Sterility & Donor Tissue Quality | AlloFuse is provided sterile and for single patient use. Donor bone meets AATB requirements. |
2. Sample Size Used for the Test Set and Data Provenance
Due to the nature of this 510(k) submission, direct "test sets" for clinical performance of the new device (AlloFuse) are not reported. The submission relies on data from the predicate device and specific lab tests for the new device:
- Viral Inactivation Validation:
- Sample Size: Not specified for the "select panel of viruses," but assumed to be multiple viruses representing various types.
- Provenance: Lab-based (in-vitro) testing of the DBM processing method.
- Osteoinductive Potential:
- Sample Size: Assumed to be adequate for "an in vivo assay to ensure osteoinductive potential of the final product," performed for every lot of final product.
- Provenance: Athymic rat model (animal study), conducted by the manufacturer.
- Product Performance Testing (Predicate Device - DynaGraft® II):
- Sample Size: Not specified for the rabbit and sheep models.
- Provenance: Animal models (rabbit, sheep), nature (retrospective/prospective) not specified but typically prospective for such studies.
- Clinical Studies (Predicate Device - DynaGraft® II):
- Sample Size: Not specified.
- Provenance: Human clinical studies, typically prospective. Country of origin not specified, but likely US-based given the FDA submission.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
Given this is a 510(k) for a device claiming substantial equivalence rather than a new drug or complex diagnostic, explicit "ground truth" established by a panel of human experts for a specific test set (like an AI study) is not detailed.
- Viral Inactivation: Ground truth would be based on established virology protocols and detection methods, likely performed by qualified microbiologists/virologists in a laboratory setting.
- Osteoinductive Potential: Ground truth is established by histological and potentially radiographic evaluation of new bone formation in the athymic rat model, assessed by experts in pathology and histology.
- Product Performance Testing (Predicate - Animal Models): Ground truth was established by radiographic and histological methods, interpreted by relevant veterinary or medical experts (e.g., veterinary radiologists, pathologists).
- Clinical Studies (Predicate - Human): Ground truth (acceptable outcomes in spinal fusions) would have been established by clinicians (e.g., orthopedic surgeons, radiologists) based on follow-up examinations, imaging, and patient outcomes.
4. Adjudication Method for the Test Set
No explicit adjudication method (e.g., 2+1, 3+1) is mentioned, as this is not an AI diagnostic study relying on human reader consensus. Outcomes from animal and human studies would be assessed via standard clinical or laboratory practices, which often involve multiple reviewers but not necessarily a formal adjudication process as seen in AI studies.
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 MRMC comparative effectiveness study was done. This 510(k) is for a bone void filler device, not an AI diagnostic tool. Therefore, there's no discussion of human readers improving with or without AI assistance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This submission is for a medical device (bone void filler), not an algorithm or AI system.
7. The Type of Ground Truth Used
- Viral Inactivation Validation: Established lab-based measurements of viral reduction.
- Osteoinductive Potential: Histological evidence of new bone formation in an in vivo athymic rat model.
- Product Performance Testing (Predicate): Radiographic and histological findings in animal models.
- Clinical Studies (Predicate): Clinical outcomes (e.g., successful spinal fusion) and patient follow-up data.
8. The Sample Size for the Training Set
Not applicable. There is no "training set" in the context of an AI algorithm for this device. The development of the manufacturing processes and material formulation would be based on general scientific knowledge and prior product development, not a labeled dataset for training an algorithm.
9. How the Ground Truth for the Training Set was Established
Not applicable. As there is no AI training set, there is no ground truth established for it.
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