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510(k) Data Aggregation
(140 days)
Device 300397 Putty
Device 300397 Putty is indicated only for bony voids or gaps that are not intrinsic to the stability of the bony structure. Device 300397 Putty is indicated to be gently packed into bony voids or gaps of the skeletal system (i.e., posterolateral spine, ilium and pelvis). These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone. The product provides a bone void filler that resorbs and is replaced with bone during the healing process.
Device 300397 Putty must be used with blood or autogenous bone marrow aspirate and autograff in posterolateral spine.
Device 300397 Putty is an osteoconductive, porous, resorbable bone graft substitute which consists of calcium phosphate granules (a-TCP and hydroxyapatite) and Type I and III porcine collagen. The single-patient, single-use product is supplied in three (3) sizes as a sterile, dry block. When mixed with autogenous bone marrow aspirate, blood or sterile non-pyrogenic saline, the product forms a moldable non-setting putty (net volume: 2.5 cc, 5 cc or 10 cc).
The provided text is a 510(k) Summary for a medical device (Device 300397 Putty), which is a premarket notification for demonstrating substantial equivalence to a legally marketed predicate device. This type of submission focuses on comparing a new device to an existing one, rather than presenting a detailed clinical study with acceptance criteria, sample sizes, and ground truth establishment in the way typically seen for a novel diagnostic or AI device.
Therefore, the requested information components related to acceptance criteria, specific study design for proving acceptance criteria for an AI/diagnostic device, sample sizes for test/training sets, expert ground truth establishment, adjudication methods, MRMC studies, and standalone performance metrics are not applicable to this document.
This document describes a device approval process based on demonstrating substantial equivalence in terms of intended use, technological characteristics, and safety and performance through various tests, primarily non-clinical, not a study designed to meet specific performance metrics against a defined ground truth for a diagnostic outcome.
However, I can extract information regarding the safety and performance studies that were conducted to support the substantial equivalence claim.
Here's a summary based on the provided document, addressing the closest relevant points:
1. Acceptance Criteria and Reported Device Performance:
The document does not specify quantitative acceptance criteria in the manner of diagnostic performance metrics (e.g., sensitivity, specificity, AUC). Instead, the "acceptance criteria" are implicitly met by successful execution and favorable results of the numerous safety and performance tests to demonstrate substantial equivalence to the predicate device. The "reported device performance" is described qualitatively through these tests.
Category | Specific Test | Description of Performance (Implicitly Meets Acceptance) |
---|---|---|
Chemical Properties | Amino Acid Composition, Product Composition, Phase Analysis, FT-IR, SEM, Molecular Weight Distribution, Onset Temperature and Enthalpy of Protein Denaturation, Enzymatic Collagen Degradation | The device components (calcium phosphate granules, porcine collagen) were characterized. The use of a different TCP polymorph compared to the predicate was deemed not to raise different safety/effectiveness concerns due to similar structural composition and chemical stoichiometry. Identified raw material sources for porcine collagen were previously cleared. |
Physical Properties | Pore Size and Pore Size Distribution, Particle Size Distribution, Weight, Dimension, and Density, Determination of Hydrated Volume | Granule size is slightly larger than the predicate but demonstrated through performance testing not to raise new concerns. |
Material Handling | N/A (Studies Conducted) | N/A |
Sterilization | ISO 11137-1:2006, ISO 11137-2:2013, and ISO 11137-3:2017 | Validation successfully executed. |
Packaging | ISO 11607-1:2019, ASTM F1980:2007, ASTM F1886/F1886M:2016, ASTM F88:2015, ASTM F1929:2015, and ASTM F2096:2011 | Validation successfully executed. |
Product Stability | ICH Q1A(R2) | N/A (Studies Conducted) |
Transport Simulation | ISTA 3A | N/A (Studies Conducted) |
Biocompatibility | ISO 10993-1:2018 (comprising Cytotoxicity, Sensitization, Irritation/Intracutaneous Reactivity, Acute Systemic Toxicity, Material Mediated Pyrogenicity, Subacute Systemic Toxicity, Subchronic Systemic Toxicity, Genotoxicity, Implantation (local tissue reaction), Hemocompatibility, Chronic Systemic Toxicity, Elemental Impurities Analysis) | Successfully executed. Local tissue reaction was evaluated in accordance with ISO 10993-6:2016. |
In Vivo Performance | NZ White Rabbit Single Level Spinal Fusion Model | Device 300397 Putty hydrated with BMA or blood and mixed 1:1 with autograft demonstrated: |
- Progression in healing vs. time when implanted on decorticated transverse processes in the posterolateral space.
- Further healing at host decorticated transverse process interfaces with new bone formation and active osteoblasts.
- New bone formation directly on the graft material surfaces.
- Confirmed progression and maturation of fusions via histology.
- Bone remodeling and new marrow spaces at the decorticated host transverse process interface, with an association with a reduction in local inflammatory cells. Performance evaluated per FDA guidance for calcium salt bone void fillers. |
2. Sample Size and Data Provenance (for test set for AI/diagnostic devices):
- Not applicable for this 510(k) submission as it's not an AI/diagnostic device.
- For the in vivo animal study, the model used was the NZ White Rabbit Single Level Spinal Fusion Model. The specific number of animals is not provided in this summary. This is a prospective animal model study.
3. Number of Experts and Qualifications (for ground truth for AI/diagnostic devices):
- Not applicable as there is no mention of establishing ground truth by human experts for a diagnostic task.
- The evaluation of the in vivo study results (e.g., histology interpretation, assessment of bone formation) would typically be performed by veterinary pathologists or experts in orthopedics/bone regeneration, but their specific number and qualifications are not detailed in this summary.
4. Adjudication Method (for test set for AI/diagnostic devices):
- Not applicable for this type of device and submission.
5. MRMC Comparative Effectiveness Study:
- No, an MRMC comparative effectiveness study for human readers with and without AI assistance was not done, as this is not an AI/diagnostic device.
6. Standalone Performance Study:
- No, a standalone algorithm-only performance study was not done, as this is not an AI/diagnostic device.
- The "standalone" performance for this device is represented by the in vivo animal study where the device's ability to promote bone healing was directly assessed.
7. Type of Ground Truth Used:
- For the in vivo animal study, the "ground truth" for assessing bone healing and tissue reaction was based on histology (microscopic examination of tissue samples) and observation of fusion progression in the animal model. This could be considered similar to "pathology" for human studies, reflecting direct biological evidence of effect.
8. Sample Size for Training Set:
- Not applicable as this is not an AI/machine learning device that requires a training set.
9. How Ground Truth for Training Set Was Established:
- Not applicable as this is not an AI/machine learning device.
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