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510(k) Data Aggregation

    K Number
    K213895
    Date Cleared
    2022-01-13

    (30 days)

    Product Code
    Regulation Number
    888.3030
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Skeletal Dynamics Inc's Distal Humerus Plating System is indicated for intra-articular fractures of the distal humerus, comminuted supracondylar fractures, osteotomies, and non-unions of the distal humerus.

    Device Description

    The Skeletal Dynamics Inc's Distal Humerus Plating System consists of five titanium bone plates in different shapes (medial direct, lateral direct, lateral capitellar, and supracondylar), in multiple lengths, and in left and right configurations to address distal humerus fractures. The plates are made of medical grade titanium allov. The system also includes 2.7mm, 3.5mm and 4.5mm locking and compression titanium alloy screws and 3.0mm polyaxial Cobalt Chrome locking screws which are provided in various lengths. The System is being modified to include additional lengths of existing screw options and new 3.5mm and 4.5mm locking and compression Titanium Alloy Screws. Additionally, minor modifications have been made to the plates to accept the new screws above mentioned. Also included in the system is specialized instrumentation. The System is provided nonsterile for sterilization in the user facility.

    The Distal Humerus Plating System is comprised of:

    • · Titanium alloy plates, screws, and fasteners
    • · CoCr Cannulated Polyaxial Locking Screws (PLS)
    • · Stainless steel K-wires (for provisional fixation; not for implantation)
    • · System specific instrumentation
    AI/ML Overview

    This document describes a medical device, the "Distal Humerus Plating System," which is a metallic bone fixation appliance. The FDA clearance is based on substantial equivalence to a predicate device, not on extensive clinical outcome studies typically associated with AI/software devices.

    Therefore, many of the requested points, particularly those related to AI algorithm performance (acceptance criteria, ground truth, expert consensus, MRMC studies, etc.), are not applicable to this type of device clearance. The clearance is based on engineering analysis and mechanical testing, ensuring the device's physical properties are safe and effective.

    Here's an analysis of the provided text in relation to your questions, highlighting what is present and what is absent:

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

    • Acceptance Criteria (for this type of device): The primary acceptance criterion for this type of medical device cleared through the 510(k) pathway is substantial equivalence to a predicate device. This means demonstrating that the new device is as safe and effective as a legally marketed device and does not raise new questions of safety or effectiveness. For metallic bone fixation, this typically involves material compatibility, mechanical strength, and design similarities.
    • Reported Device Performance: The document states:
      • "Engineering analysis and mechanical testing demonstrated that the Skeletal Dynamics Inc's Distal Humerus Plating System is equivalent to predicate devices currently marketed."
      • "Static testing, which established equivalency included ASTM-F543-17 Standard Specification and Test Methods for Metallic Medical Bone Screws."
      • "The subject device is as safe and effective as the legally marketed predicate device."

    Table of Acceptance Criteria and Performance (as applicable to this device type):

    Acceptance Criteria CategorySpecific Criteria (Implicitly Met for 510(k))Reported Device Performance
    Substantial EquivalenceEquivalence in Intended Use, Indications for Use, Materials, Design (Fundamental Scientific Technology), Performance, Sterility, and Packaging."demonstrated that the Skeletal Dynamics Inc's Distal Humerus Plating System is equivalent to predicate devices currently marketed."
    Material PropertiesBiocompatibility, appropriate material strength and longevity (Titanium alloy, CoCr).Made of "medical grade titanium alloy" and "CoCr." Implies meeting standard material specifications.
    Mechanical PerformanceMechanical strength and stability sufficient for intended use (bone fixation)."Engineering analysis and mechanical testing demonstrated...Static testing, which established equivalency included ASTM-F543-17 Standard Specification and Test Methods for Metallic Medical Bone Screws."
    Safety & EffectivenessNo new issues of safety or effectiveness compared to predicate."does not present any new issues of safety or effectiveness." "The subject device is as safe and effective as the legally marketed predicate device."

    2. Sample sized used for the test set and the data provenance

    • Not Applicable. This is a hardware device cleared through a 510(k) pathway, not an AI/software device requiring a test set of medical images or patient data in the sense of an algorithm. The "testing" refers to mechanical and engineering tests, not data sets.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    • Not Applicable. See point 2. Ground truth in the context of AI relates to expert labels on data. For this device, "ground truth" relates to engineering standards and validated test methods.

    4. Adjudication method for the test set

    • Not Applicable. See point 2.

    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. This is a physical implantable device, not an AI-assisted diagnostic tool. MRMC studies are used for evaluating the impact of AI on human interpretation of medical images.

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

    • Not Applicable. This is not an algorithm.

    7. The type of ground truth used

    • Ground Truth (for this device type): Engineering specifications, validated mechanical testing standards (e.g., ASTM-F543-17), and material properties are the "ground truth" against which the device's performance is measured for substantial equivalence. There isn't "expert consensus" or "pathology" in the sense of clinical image interpretation for this specific clearance.

    8. The sample size for the training set

    • Not Applicable. This is a hardware device, not an AI algorithm requiring a training set.

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

    • Not Applicable. See point 8.

    In summary: The provided FDA clearance document for the "Distal Humerus Plating System" pertains to a physical medical device. The regulatory pathway (510(k)) relies on demonstrating substantial equivalence to a predicate device, primarily through engineering analysis and mechanical testing. The questions you posed are highly relevant to AI/machine learning medical devices, but not to this specific hardware device clearance.

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    K Number
    K200367
    Date Cleared
    2020-05-14

    (90 days)

    Product Code
    Regulation Number
    888.3030
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Skeletal Dynamics Distal Humerus Plating System is indicated for intra-articular fractures of the distal humerus, comminuted supracondylar fractures, osteotomies, and non-unions of the distal humerus.

    Device Description

    The Skeletal Dynamics Distal Humerus Plating System consists of five titanium bone plates in different shapes (medial direct, lateral direct, lateral capitellar, and supracondylar), in multiple lengths, and in left and right configurations to address distal humerus fractures. The plates are made of medical grade titanium alloy. Locking and compression screws in 2.7mm, 3.5mm and 4.5mm and 3.0mm polyaxial locking screws are provided in various lengths. Also included in the system is specialized instrumentation. The System is provided non-sterilization in the user facility.

    The Distal Humerus Plating System is comprised of:

    • . Titanium alloy plates, screws and fasteners
    • CoCr Cannulated Polyaxial Locking Screws (PLS) .
    • Stainless steel K-wires (for provisional fixation: not for implantation) ●
    • System specific instrumentation ●
    AI/ML Overview

    The provided text is a 510(k) summary for a medical device called the "Distal Humerus Plating System," which is a metallic bone fixation appliance. It describes the device, its indications for use, and how its substantial equivalence to predicate devices was demonstrated through mechanical testing.

    However, the request asks for information related to "acceptance criteria" and "study that proves the device meets the acceptance criteria" in the context of an AI/Software as a Medical Device (SaMD). The provided document does not describe an AI/SaMD device; instead, it describes a hardware device (bone plates and screws) and the performance testing (mechanical testing, specifically ASTM standards) done to demonstrate its equivalence to predicate devices.

    Therefore, I cannot fulfill all aspects of your request because the document does not contain information about:

    • A table of acceptance criteria and reported device performance related to AI metrics (e.g., sensitivity, specificity, AUC).
    • Sample sizes for test sets in the context of AI (e.g., number of images).
    • Data provenance for AI test sets.
    • Number of experts and their qualifications for establishing ground truth for AI.
    • Adjudication methods for AI test sets.
    • MRMC studies for AI and human-in-the-loop performance.
    • Standalone performance for an AI algorithm.
    • Types of ground truth for AI (e.g., pathology, outcomes data).
    • Sample size for AI training sets.
    • How ground truth for AI training sets was established.

    The document focuses on the mechanical and material equivalence of a physical implantable device.

    Here's what can be extracted and inferred from the provided text, reinterpreted as much as possible for your request, but with the explicit understanding that it's not an AI/SaMD context:

    Device Description:
    The Skeletal Dynamics Distal Humerus Plating System is a physical medical device consisting of titanium bone plates, locking and compression screws, and specialized instrumentation, designed for fixing fractures of the distal humerus.

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

    Since this is a physical device, the "acceptance criteria" and "performance" are based on mechanical equivalency to predicate devices.

    Acceptance Criteria (Implied)Reported Device Performance
    Mechanical properties equivalent to predicate devicesDemonstrated equivalency through ASTM F382 and ASTM F543 testing.
    Safe and effective as legally marketed predicate devicesSubject device is concluded to be as safe and effective as predicate devices.
    Compliance with ASTM F382 (Metallic Bone Plates) standardsMet (stated a study included this standard)
    Compliance with ASTM F543 (Metallic Bone Screws) standardsMet (stated a study included this standard)

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

    • Test Set Sample Size: Not explicitly stated as "sample size" in the context of a discrete number of tests on identical units, but indicated to be sufficient to demonstrate equivalency according to ASTM standards. ASTM standards define the number of samples typically required for such tests.
    • Data Provenance: The "study" is an engineering analysis and mechanical testing performed to demonstrate equivalency. The data provenance would be laboratory testing conducted by the manufacturer or a third-party lab. No information on country of origin of "data" in a clinical/retrospective sense, as this is pre-market mechanical testing.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Not applicable in the context of mechanical testing. The "ground truth" for mechanical testing is established by the specified parameters and methodologies within the ASTM standards themselves, interpreted and executed by qualified engineers and technicians. This is not about human labelers/readers.

    4. Adjudication method for the test set:

    • Not applicable. This is mechanical testing against defined engineering standards, not human expert 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:

    • Not applicable. This device is a physical implant, not an AI or imaging device that would involve human readers.

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

    • Not applicable. No algorithm is involved.

    7. The type of ground truth used:

    • The "ground truth" for the performance testing of this physical device is the mechanical and material specifications and performance parameters outlined in the referenced ASTM standards (ASTM F382 for plates and ASTM F543 for screws) and the performance characteristics of the legally marketed predicate devices.

    8. The sample size for the training set:

    • Not applicable. This is not an AI/machine learning device that requires a "training set."

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

    • Not applicable.

    In summary, the provided document details the regulatory clearance of a physical orthopedic implant based on demonstrating mechanical equivalence to existing products, not an AI/SaMD product. Therefore, most of your specific questions related to AI/SaMD testing and ground truth cannot be answered from this text.

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