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510(k) Data Aggregation

    K Number
    K060428
    Date Cleared
    2006-03-07

    (14 days)

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

    The CSS Cannulated Screw System will be indicated for use in long and small bone fracture fixation, which includes the following;

    • Fractures of the tarsals and metatarsals
    • Fractures of the olecranon, distal humerous
    • Fractures of the radius and ulna
    • Patella fractures
    • Distal tibia and pilon fractures
    • Fractures of the fibula, medial malleolus, os calcis
    • Tarso-metatarsal and metatarsal phalangeal arthrodesis
    • Metatarsal and phalangeal osteotomies
    • Osteochondritis dissecans
    • Ligament fixation
    • Other small fragment, cancellous bone fractures and osteotomies
    Device Description

    The CSS Cannulated Screw System consists of cannulated screws of various diameters, lengths and thread configurations. The system also includes correspondingly sized washers, the use of which are optional, as well as guide wire and various instruments.
    The cannulated screws are self tapping. They are made from made from Titanium Ti-6Al-4V ELI Alloy in conformance with ASTM F-136 Standard Specification for Wrought Titanium 6Al-4V ELI Alloy for Surgical Implant Applications.
    The CSS System includes (4) different types of washers. These are; Flat Washers, Contoured Washers, Partial Contoured Washers, and Domed Washers. The various styles are intended to offer the surgeon a variety of anatomical fit to the bone in certain applications.

    AI/ML Overview

    The provided text describes the CSS Cannulated Screw System and its substantial equivalence to a predicate device, the Howmedica Asnis III Cannulated Screw System (K000080).

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance Criteria (Performance Measure)Reported Device Performance (CSS Cannulated Screw System)
    Substantial Equivalence to Predicate Device (Howmedica Asnis III) in terms of mechanical performance.Results clearly demonstrate that the CSS System is substantially equivalent to its' predicate based on Finite Element Analysis (FEA) and performance testing.

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

    The document does not specify a separate "test set" in the context of clinical data for the device's performance. The performance evaluation was primarily mechanical and computational.

    • Sample size for test set: Not applicable in the context of human data. For the mechanical and computational analysis, the "samples" would refer to the designs modeled and tested. The document implies a comparison of the CSS Cannulated Screw System against the predicate device.
    • Data provenance: Not applicable. The data is from in-vitro mechanical testing and computational modeling (Finite Element Analysis) performed by the manufacturer, OrthoHelix Surgical Designs, Inc.

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

    Not applicable. Ground truth in this context refers to mechanical properties and substantial equivalence, not clinical diagnostic accuracy or efficacy requiring expert consensus for a test set.

    4. Adjudication Method for the Test Set:

    Not applicable. This concept pertains to resolving discrepancies in expert interpretations of clinical data, which is not relevant to this type of device submission.

    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. The CSS Cannulated Screw System is a physical medical device (cannulated screws) for orthopedic fixation, not a software or AI-driven diagnostic tool. Therefore, an MRMC study or AI assistance is not relevant.

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

    Not applicable. As noted above, this device is not an algorithm or AI system.

    7. The Type of Ground Truth Used:

    The "ground truth" for demonstrating substantial equivalence was the known mechanical performance and design specifications of the legally marketed predicate device, the Howmedica Asnis III Cannulated Screw System. This served as the benchmark against which the CSS Cannulated Screw System's performance (via FEA and performance testing) was compared.

    8. The Sample Size for the Training Set:

    Not applicable. The concept of a "training set" typically refers to data used to train machine learning models and is not relevant to the evaluation of this physical medical device. The design and materials are based on established engineering principles and materials science for medical implants.

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

    Not applicable. As there is no training set in the context of machine learning, no ground truth was established for it. The design and manufacturing process would adhere to established standards (e.g., ASTM F-136) and engineering best practices for orthopedic implants.

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    K Number
    K031564
    Device Name
    CSS
    Date Cleared
    2003-10-07

    (141 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CSS is intended to be used in conjunction with the powered debrider cutter systems to cut and coagulate soft tissue during various arthroscopic surgical procedures.

    Device Description

    The CSS is an accessory device that is intended to be used in conjunction with currently marketed automated debrider systems and ESU's the same as the current MSI Bipolar Sheath. The CSS is designed to fit directly over various sizes of straight automated debrider system blades. The CSS will be available in a variety of diameters and in lengths. When the CSS is inserted over one of the debrider blades, the device may be used to cauterize tissue. The CSS can be utilized to provide spot coagulation or to coagulate tissue while the debrider blade is in operation.

    AI/ML Overview

    The provided text describes a 510(k) summary for the "CSS" (Coagulation Device) a modification to the MSI Bipolar Sheath. This document focuses on demonstrating substantial equivalence to predicate devices, rather than presenting a performance study with detailed acceptance criteria and supporting data for a novel device. Therefore, much of the requested information regarding acceptance criteria, study design, and ground truth establishment is not available in the provided text.

    Here's a breakdown of what can be extracted and what is missing:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance CriteriaReported Device Performance
    Substantial Equivalence in design, materials, construction, and intended use as predicate devices.The CSS is stated to be "substantially equivalent in design, materials, construction and intended use" to the predicate devices (MSI Bipolar Sheath, K011202; Stryker Serfac K991960).
    Does not raise new safety and efficacy concerns compared to similar legally marketed devices.The document explicitly states, "the CSS does not raise any new safety and efficacy concerns when compared to these similar legally marketed devices."
    Functionality and conformance to design input requirements."Bench testing was conducted to determine device functionality and conformance to design input requirements." (No specific criteria or results are provided, only that testing was conducted.)
    Differences in power are substantiated through applicable performance testing."The differences in power have been substantiated through applicable performance testing." (No specific criteria or results are provided.)

    Missing Information:

    • Specific quantitative or qualitative acceptance criteria beyond "substantially equivalent" and "no new safety/efficacy concerns."
    • Detailed performance metrics (e.g., coagulation time, tissue effect, safety margins for specific power differences).
    • Actual data demonstrating how the device met these criteria.

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

    • Sample Size: Not specified. The document only mentions "Bench testing."
    • Data Provenance: Not specified. It's bench testing, so likely conducted in a lab setting, but no country of origin is mentioned. The testing is retrospective, as it's for verification of a device.

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

    • Not applicable. The study involved bench testing, not human interpretation or clinical data requiring expert ground truth establishment in the traditional sense.

    4. Adjudication Method for the Test Set:

    • Not applicable. As this was bench testing, there's no mention of an adjudication method among experts.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

    • No, an MRMC study was not done. This device is an accessory for surgical procedures, and the testing described is bench testing, not a clinical study involving human readers interpreting cases.

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

    • Yes, in a way. The "bench testing" can be considered a standalone performance evaluation of the device itself (not an algorithm), without human-in-the-loop performance influencing the device's basic functionality. However, it's not "algorithm only" as there's no explicit algorithm described.

    7. The Type of Ground Truth Used:

    • For the bench testing, the "ground truth" would be engineering specifications and design input requirements for functionality, materials, and power characteristics. This is based on engineering/design specifications for the device.

    8. The Sample Size for the Training Set:

    • Not applicable. There is no mention of a "training set" as this is not an AI/machine learning device. The testing described is for a physical medical device.

    9. How the Ground Truth for the Training Set was Established:

    • Not applicable, as no training set is mentioned.

    In summary, the provided document describes a 510(k) submission for a medical device accessory (CSS) that relies on demonstrating substantial equivalence through bench testing to established predicate devices. It does not provide the detailed study design, specific acceptance criteria, or quantitative results typical of studies for novel devices or AI/software as a medical device (SaMD).

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    K Number
    K973237
    Date Cleared
    1998-04-27

    (242 days)

    Product Code
    Regulation Number
    870.4370
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Medtronic CSS™ Cardioplegia Safety System is intended for use as a cardioplegia delivery system which controls, monitors, and delivers oxygenated blood and/or asanguineous solutions during cardiopulmonary bypass procedures.

    Device Description

    The Medtronic CSS Cardioplegia Safety System Model 990 consists of an electro-mechanical instrument and disposable Cardioplegia Sets. The instrument delivers cardioplegia solution through dual peristaltic independently operated pumps (one for blood, one for crystalloid). It monitors volume delivered, flow rate (adjustable from 0 - 990 ml/min), and pressure (line and external). It also includes temperature monitoring capabilities, gross air detection using ultrasonic technology, and two independent elapsed timers. The instrument has a color central information display and a two-stage alert-alarm process. It has battery backup for 60 minutes of "On" time and 15 minutes of pumping time. The disposable sets are single use, sterile, and nonpyrogenic, designed to mix arterial blood and asanguineous cardioplegia solution at various ratios. The sets include silicone tubing and polycarbonate connectors and are available in four configurations, with or without a heat exchanger and with standard or dual lumen patient lines.

    AI/ML Overview

    The Medtronic CSS Cardioplegia Safety System Model 990 is intended for use as a cardioplegia delivery system which controls, monitors, and delivers oxygenated blood and/or asanguineous solutions during cardiopulmonary bypass procedures. The provided document is a 510(k) summary, which focuses on demonstrating substantial equivalence to predicate devices rather than fully detailing a study against specific acceptance criteria for novel performance claims. However, it does present performance data for various features of the device as part of the substantial equivalence argument, which can be interpreted as meeting certain "acceptance criteria" by comparing them to predicate devices or manufacturer's specifications.

    Here's an analysis of the acceptance criteria and the study as presented:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document provides a comparative table where the Medtronic CSS's features and performance specifications are listed alongside those of predicate devices (Sorin BCC, Quest MPS, Sarns 9000). While it doesn't explicitly state "acceptance criteria" as pass/fail thresholds for clinical claims, the comparison table implicitly defines the acceptable performance range by demonstrating equivalence to already cleared devices or meeting internal specifications.

    Feature AreaImplicit Acceptance Criteria / Predicate Performance (Range from table)Medtronic CSS Reported Device PerformanceStudy/Test Performed
    Pressure Range0-990 mmHg (Sarns); 0-550 mmHg (Sorin); 0-600 mmHg (Quest)0-500 mmHg (Also, pump mechanism will not generate > 1200mmHg; shuts down if > 500 mmHg)In-Vitro Bench Testing: Occlusion and Maximum Pressure, Line Pressure Measurement System Performance, External Pressure Measurement
    Line Pressure Accuracy+/- 5 mmHg (Sorin); +/-2.5% or 3mmHg (Quest); +/-10-20 mmHg (Sarns)0-100 mmHg +/-10 mmHg; 101-500 mmHg +/-10%In-Vitro Bench Testing: Line Pressure Measurement System Performance
    External Pressure Accuracy+/- 5 mmHg (Sorin); +/-2.5% or 3mmHg (Quest); +/-10-20 mmHg (Sarns)0-100 mmHg +/- 5 mmHg; 101-500 mmHg +/-5%In-Vitro Bench Testing: External Pressure Measurement
    Constant Pressure ModeYes (Quest, Medtronic CSS); N/A (Sorin, Sarns)Pressure maintained at +/-15% of target; flow varies no more than +/-25%In-Vitro Bench Testing: Constant Pressure Mode Performance
    Flow Rate0-9.8 L/min (Sarns); 10-600 mL/min (Sorin); 0-500 mL/min (Quest)0-990 mL/minIn-Vitro Bench Testing: Pump Flow Performance
    Flow Accuracy+/-5% (Sorin, Quest); +/-0.1-0.3 L/min (Sarns)0-600 +/- 10% *; 601-990 +/- 20%In-Vitro Bench Testing: Pump Flow Performance
    Temperature Range0-50°C (Medtronic CSS); 0-40°C (Sorin); 0-39°C (Quest); 0-49.9°C (Sarns)0-50°CIn-Vitro Bench Testing: Temperature Monitoring
    Temperature Accuracy+/-1°C (Sorin, Quest, Medtronic CSS); +/-0.2°C (Sarns)+/-1°CIn-Vitro Bench Testing: Temperature Monitoring
    Timer Range0-99hr59min59sec (Medtronic CSS); 0-99.9 min (Sorin); 0-24 hrs (Sarns)0-99hr59min59secNot explicitly detailed, but part of functional testing
    Timer Accuracy1 sec (Medtronic CSS); 0.1 min (Sorin); +/- 1 min (Sarns)1 secNot explicitly detailed, but part of functional testing
    Gross Air DetectionYes (Quest, Sarns, Medtronic CSS); No (Sorin)Detects gross air (air bubble of at least 1/4" diameter)In-Vitro Bench Testing: Gross Air Detection
    Battery Back-upYes (Sorin, Sarns, Medtronic CSS); No (Quest)60 min "On" time, 15 min pumping timeIn-Vitro Bench Testing: Battery Back-up
    Air Detection TransducerUses ultrasonic detection technologyUses ultrasonic detection technology for gross airIn-Vitro Bench Testing: Gross Air Detection
    Disposable Set IntegrityN/A (specific to Medtronic CSS)Operated in accordance with Medtronic Bio-Medicus device specificationsIn-Vitro Bench Testing: The CSS™ Instrument Disposable Set Integrity Test
    Blood TraumaN/A (specific to Medtronic CSS)Operated in accordance with Medtronic Bio-Medicus device specificationsIn-Vitro Bench Testing: Blood Trauma Test
    BiocompatibilityMaterials commonly used in medical industry; tested per FDA/ISOMaterials determined to be biocompatible and nontoxicBiocompatibility Testing
    SterilizationN/A (specific to Medtronic CSS)Validated 100% (EtO) at min SAL of $10^{-6}$ per ANSI/AAMI/ISO 11135-1994Sterilization Validation
    EtO ResidualsN/A (specific to Medtronic CSS)Meets limits per ANSI/AAMI/ISO 10993-7:1995EtO Residuals Testing
    Pyrogen TestingN/A (specific to Medtronic CSS)Less than 0.5 EU/ml per FDA guidelines (Dec 1987)Pyrogen Testing (LAL method)

    * "Based on customer input this accuracy is sufficient for this application"

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

    The document describes "In-Vitro Bench Testing" and "Biocompatibility Testing."

    • Test Set Sample Size: Not explicitly stated for any of the individual bench tests. The document only lists the types of tests conducted. For biocompatibility, it states "these devices were tested," implying a sample was used but no number is provided.
    • Data Provenance: The tests described are "In-Vitro Bench Testing" and "Biocompatibility Testing." This indicates the data is from retrospective laboratory experiments conducted by the manufacturer, Medtronic Bio-Medicus, Inc. There is no mention of human subject data or data from specific countries of origin beyond the company's location in Eden Prairie, MN, USA.

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

    Not applicable. This device is a cardioplegia delivery system, and the studies performed are bench tests and biocompatibility tests. There is no diagnostic component requiring human expert ground truth for interpretation of medical images or patient conditions. The "ground truth" for these tests would be the established engineering specifications, chemical/biological standards, and physical measurements.

    4. Adjudication Method for the Test Set

    Not applicable, as expert adjudication is not relevant for bench or biocompatibility testing. The "adjudication" would involve comparing test results against predefined engineering specifications and regulatory standards.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No, a Multi-Reader Multi-Case comparative effectiveness study was not done. This type of study is typically performed for diagnostic or screening devices where human readers (e.g., radiologists) interpret images or data, and their performance with and without AI assistance is compared. The Medtronic CSS Cardioplegia Safety System is a therapeutic delivery system with monitoring capabilities, so an MRMC study is not relevant to its function and claims.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    Yes, the "In-Vitro Bench Testing" and "Biocompatibility Testing" can be considered standalone performance evaluations. These tests assess the device's intrinsic mechanical, electrical, and material properties and performance against specifications without direct human-in-the-loop interaction for the specific performance endpoint being measured (e.g., pump flow accuracy, pressure detection, air bubble detection). The control system (microprocessor, software) within the instrument operates autonomously during these tests to fulfill its functions.

    7. Type of Ground Truth Used

    The ground truth for the various tests appears to be:

    • Engineering Specifications: For parameters like flow accuracy, pressure accuracy, temperature accuracy, timer accuracy, and constant pressure mode performance, the ground truth is the device's designed operational specifications and performance limits. These are then compared to the measured performance.
    • Physical Measurements: Directly measured flow rates, pressures, temperatures, and times.
    • Biological/Chemical Standards: For biocompatibility, the ground truth is established by recognized international standards (ISO 10993-1, USP XXIII) and FDA guidelines. For EtO residuals, it's ANSI/AAMI/ISO 10993-7:1995. For pyrogen testing, it's FDA guidelines.
    • Visual/Physical Detection: For gross air detection, the ground truth would be the presence of a known air bubble of a specified size.

    8. Sample Size for the Training Set

    Not explicitly stated. As this is a 510(k) for a hardware device with embedded software (not a machine learning/AI diagnostic system generating models from data), the concept of a "training set" in the context of statistical modeling or AI development is not directly applicable in the way it is for imaging algorithms. Any "training" or calibration would likely refer to internal iterative development and testing against specifications, rather than data-driven model training.

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

    Not applicable in the typical AI/ML sense. For hardware and embedded software development, the "ground truth" during development (if we were to loosely interpret "training set" as development data) would be established by engineering design specifications, safety standards, and performance targets derived from clinical requirements and predicate device performance. This would involve rigorous internal testing, debugging, and verification to ensure the device performs as designed.

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