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510(k) Data Aggregation

    K Number
    K203405
    Date Cleared
    2021-01-27

    (69 days)

    Product Code
    Regulation Number
    888.3030
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    EVOS Large Fragment Plating System

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The EVOS Large Fragment Plating System is indicated for adult patients. It is indicated for fixation of long bone fractures.

    Device Description

    Subject of this premarket notification is an extension of the EVOS Large Fragment Plating System, the Peri-Prosthetic Plates, Blunt Tip Screws and Cable Accessories. The proposed devices incorporate design features similar to those currently incorporated on previously cleared Smith & Nephew bone plate and screw systems. Like their previously cleared counterparts. the proposed plates feature a screw-to-plate locking feature that permits their use with the previously cleared and compatibility designed locking and non-locking screws described in this premarket notification. EVOS Large Fragment Per-Prosthetic Plates are available in a variety of plate designs for specific anatomical areas. These plate designs have a combination of 3.5mm and 4.5mm holes. Plate designs may include threaded holes, non-threaded holes, and variable-angle locking holes. Blunt Tip Screws are available in 4.5mm diameter and are identical to the EVOS 4.5mm Cortex Locking Screws described in K201918 with the exception of the blunt tip. Cable Accessories include 3.5mm and 4.5mm cable saddles and 3.5mm cable post.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the "EVOS Large Fragment Plating System Peri-Prosthetic" by Smith & Nephew, Inc. This submission focuses on establishing substantial equivalence to previously cleared predicate devices, primarily through engineering and mechanical testing. As such, the information typically found in clinical studies involving acceptance criteria for device performance in terms of clinical outcomes, human reader improvement, or stand-alone AI performance is not applicable or present.

    Here's the breakdown of the information requested, based on the provided document:

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

    Since this is a 510(k) for a metallic bone fixation system, "acceptance criteria" and "device performance" are primarily evaluated through mechanical and pre-clinical testing, ensuring the new device performs similarly or superiorly to predicate devices. Clinical performance metrics like sensitivity, specificity, or accuracy (common for AI/diagnostic devices) are not relevant here.

    Acceptance Criteria (General)Reported Device Performance
    Mechanical Strength & Durability: Maintain structural integrity and function under simulated physiological loads, demonstrating equivalence or superiority to predicate devices in fatigue.Fatigue Performance: "Results of the testing determined that the subject plates performed similar or superior to the predicate plates tested, when evaluated under the same conditions."
    Material Biocompatibility: Materials used must be biocompatible.Biocompatibility Testing: "EVOS Large Fragment Fracture Plating System Biocompatibility Testing" (Completed, implies met criteria)
    Sterility: Device must be sterile and maintain sterility until use.Bacterial Endotoxin Testing: "Completed and met the acceptable endotoxin limits as stated in the FDA Guidance..."
    MRI Safety & Compatibility: Device must not pose a safety risk or significantly interfere with MRI procedures.MRI Compatibility Testing: "Conducted as per the FDA's guidance 'Establishing Safety and Compatibility of Passive Implants in the Magnetic Resonance (MR) Environment', December 11, 2014." (Completed, implies met criteria)
    Packaging Integrity: Packaging must protect the device and maintain sterility during transport and storage.Packaging Verification Testing: "Conducted for the proposed packaging configurations and the results of this testing demonstrated that the product will not be damaged during shipment and will adequately maintain sterility post shipment."
    Design Equivalence/Similarity: Design features (screw-to-plate locking, hole types, screw dimensions) should be similar to predicate devices.Technological Characteristics: "The proposed devices are substantially equivalent to legally marketed predicates with respect to intended use, indications, and performance characteristics." "The holes are identical to those used in the EVOS Large Fragment Plates cleared via K201918. The subject screws feature a hex drive and are identical to existing Smith & Nephew predicate screws with respect to threadform and major and minor diameter."

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document primarily discusses pre-clinical and mechanical testing. For mechanical fatigue testing, "worst case plate designs identified through FEA" were used. The sample sizes for these tests (e.g., number of plates or constructs tested) are not specified in the provided text. Data provenance (country of origin, retrospective/prospective) is not applicable or stated for this type of testing.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    This is not applicable to the type of device and submission described. Ground truth established by medical experts (like radiologists for imaging devices) is not relevant for a substantial equivalence claim based on mechanical performance of bone plates.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. Adjudication methods are typically used in clinical studies to resolve discrepancies in expert opinions, which isn't the focus of this pre-clinical mechanical evaluation.

    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. An MRMC study is relevant for diagnostic imaging devices, especially those involving AI assistance, to assess the impact of AI on human reader performance. This device is a surgical implant.

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

    Not applicable. "Standalone performance" refers to the performance of an AI algorithm without human intervention, again, relevant for diagnostic AI devices, not surgical implants.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    For the mechanical testing, the "ground truth" would be established by engineering standards and validated testing methodologies. For example:

    • Mechanical Strength: Defined by industry standards (e.g., ASTM, ISO) for bone plates, or by direct comparison to the mechanical properties of predicate devices under equivalent loading conditions. The "ground truth" is that the device must meet or exceed these established engineering performance benchmarks.
    • Biocompatibility: Established by adherence to ISO 10993 series standards.
    • Sterility: Established by microbiology standards and endotoxin limits.

    8. The sample size for the training set

    Not applicable. "Training set" refers to data used to train an AI algorithm. This device is a metallic bone fixation system, not an AI/software device requiring a training set.

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

    Not applicable, as there is no AI training set for this device.

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    K Number
    K201918
    Date Cleared
    2020-11-16

    (129 days)

    Product Code
    Regulation Number
    888.3030
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    EVOS Large Fragment Plating System

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The EVOS Large Fragment Plating System is indicated for adult patients. It is indicated for fixation of long bone fractures.

    Device Description

    Subject of this premarket notification is the EVOS Large Fragment Plating System. The proposed devices incorporate design features similar to those currently incorporated on previously cleared Smith & Nephew bone plate and screw systems. Like their previously cleared counterparts, the proposed plates feature a screw-to-plate locking feature that permits their use with the proposed and compatibility designed locking and non-locking screws described in this premarket notification. It is comprised of a variety of locking and non-locking 4.5mm straight plates, 3.5mm and 4.5mm anatomical plates as well as previously cleared 3.5mm locking and non-locking screws and new 4.5mm locking and non-locking screws, 5.7mm cannulated locking screws, 6.5mm locking and nonlocking screws, and 6.7mm high-torque (osteopenia) screws.

    AI/ML Overview

    The provided text describes the EVOS Large Fragment Plating System, a medical device for bone fracture fixation. The document details the pre-clinical testing conducted to demonstrate substantial equivalence to previously cleared predicate devices.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Test TypeAcceptance CriterionReported Device Performance
    Bending Performance (Static/Cantilever Bend Testing or Construct Fatigue Testing)The subject plates should perform similar or superior to the predicate plates tested, when evaluated under the same conditions. (Identified through FEA as "worst case" plates)Results determined that the subject plates performed similar or superior to the predicate plates tested, when evaluated under the same conditions.
    Locking Mechanism Performance (4.5mm Screws - Static Cantilever Bending and Fatigue)The results should meet the acceptance criteria in that they were similar or superior (higher) than the predicates. (Evaluated through the threaded locking mechanism and variable angle locking holes)The results met the acceptance criteria in that they were similar or superior (higher) than the predicates.
    Torque to Failure Testing (4.5mm Bone Screws)The static torsional performance of the EVOS screws should be similar to the static torsional performance of a previously cleared predicate device. (Following ASTM F543 guidelines)The acceptance criterion was met in that the static torsional performance of the EVOS screws was found to be similar to the static torsional performance of a previously cleared predicate device.
    Axial Pull-out Testing (4.5mm, 5.7mm, 6.5mm, 6.7mm Screws)The subject screws should show similar or superior (higher) pull-out strength compared to the predicates OR meet the performance criteria from FDA Guidance for Orthopedic Non-Spinal Metallic Bone Screws and Washers – Performance Criteria for Safety and Performance Based Pathway. (Following ASTM F543 guidelines)The acceptance criterion was met in that the subject screws that were tested showed similar or superior (higher) pull-out strength compared to the predicates or met the performance criteria from FDA Guidance for Orthopedic Non-Spinal Metallic Bone Screws and Washers – Performance Criteria for Safety and Performance Based Pathway.
    Magnetic Resonance Imaging (MRI) Compatibility TestingCompliant with FDA's guidance "Establishing Safety and Compatibility of Passive Implants in the Magnetic Resonance (MR) Environment", December 11, 2014.Testing was conducted as per the FDA's guidance. (Results are implied to have met the criteria as there is no mention of failure)
    Packaging Verification TestingThe product will not be damaged during shipment and will adequately maintain sterility post shipment.The results of this testing demonstrated that the product will not be damaged during shipment and will adequately maintain sterility post shipment.
    Bacterial Endotoxin TestingMet acceptable endotoxin limits as stated in specific FDA Guidance documents and ANSI/AAMI ST72.Testing was completed and met the acceptable endotoxin limits as stated in the FDA Guidance, "Submission and Review of Sterility Information in Premarket Notification (510(k)) Submissions for Devices Labeled as Sterile," "Pyrogen and Endotoxins Testing: Questions and Answers," and ANSI/AAMI ST72.
    Biocompatibility Testing(Implicitly, the device should be biocompatible as per relevant standards and guidance.)EVOS Large Fragment Fracture Plating System Biocompatibility Testing conducted. (Results are implied to have met the criteria)

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

    • The document does not explicitly state specific sample sizes for each mechanical test. Instead, it refers to evaluating "worst case plate designs" identified through Finite Element Analysis (FEA). While FEA itself is a computational method, the subsequent mechanical testing would involve a physical sample size. This information is a major gap in the provided text.
    • The data provenance is pre-clinical testing, meaning it was conducted in a laboratory setting, not on human subjects. There is no information regarding country of origin of the data provided in the FDA letter.
    • The testing is retrospective in the sense that it compares the new device to existing predicate devices already on the market.

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

    • This information is not applicable as the studies described are pre-clinical mechanical and material tests, not clinical studies involving human patients or expert interpretation of medical images. "Ground truth" in this context refers to established engineering standards (e.g., ASTM F543) and performance characteristics of predicate devices against which the new device's performance is measured.

    4. Adjudication Method for the Test Set:

    • This information is not applicable for pre-clinical mechanical and material testing. Adjudication methods (like 2+1, 3+1) are typically used in clinical trials involving human subjects where multiple experts evaluate outcomes or images.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:

    • No, an MRMC comparative effectiveness study was not done. This type of study is relevant for diagnostic imaging devices or AI-assisted clinical decision support tools where human readers (e.g., radiologists) interpret cases with and without AI assistance. The EVOS Plating System is a surgical implant, not a diagnostic or AI-driven tool.

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

    • No, this is not applicable. The device is an orthopedic implant, not a software algorithm.

    7. The Type of Ground Truth Used:

    • For the mechanical and material tests, the "ground truth" used for comparison falls into these categories:
      • Predicate Device Performance: The primary ground truth is the established performance characteristics of the legally marketed predicate devices (e.g., Smith & Nephew Locking Bone Plate System (PERI-LOC)).
      • Standardized Performance Criteria: For screws, specific FDA Guidance documents (e.g., "FDA Guidance for Orthopedic Non-Spinal Metallic Bone Screws and Washers – Performance Criteria for Safety and Performance Based Pathway") and international standards (e.g., ASTM F543, ANSI/AAMI ST72) serve as ground truth for acceptance.

    8. The Sample Size for the Training Set:

    • This information is not applicable. There is no "training set" in the context of mechanical pre-clinical testing for a surgical implant. Training sets are used in machine learning and AI development. The Finite Element Analysis (FEA) performed could be considered a form of "computational modeling" that informs the physical testing, but it's not a "training set" in the AI sense.

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

    • This information is not applicable as there is no "training set." The performance targets for the device were established based on the characteristics of predicate devices and relevant industry/regulatory standards.
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