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510(k) Data Aggregation

    K Number
    K222423
    Date Cleared
    2023-03-23

    (224 days)

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

    The non-absorbable suture anchors are intended to reattach soft tissue to bone in orthopedic surgical procedures. The Fixone All Suture Anchors may be used in either arthroscopic or open surgical procedures. After the suture strands are anchored to the bone, they may be used to reattach soft tissue, such as ligaments, tendons, or joint capsules to the bone. In conjunction with appropriate postoperative immobilization throughout the healing period, the suture anchor systems stabilize the damaged soft tissue.

    Device Description

    Fixone All suture anchor consists of one "fix Suture" and one,two or three non-absorbable Sutures. The nonabsorbable suture is manufactured from UHMWPE. They are pre-loaded on a handled insertion device. This device is provided sterile, for single use only. This device is medical device. Prescription use only.

    The color additive copper-phthalocyanine blue, color additive D&C green 6, color additive D&C violet 2 and color additive D&C black 4 are according to FDA regulations and it is approved for use in medical applications (§74.3045 – FDA), (§74.3206 –FDA), (§74.1602 –FDA) and (§74.3054 – FDA) respectively.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for a medical device called "Fixone All Suture Anchor." This document primarily deals with the substantial equivalence of a new version of the suture anchor to previously cleared predicate devices. It focuses on engineering and biocompatibility testing rather than clinical study data involving AI or human readers evaluating image-based diagnostics.

    Therefore, the information required to answer the prompt regarding acceptance criteria and study that proves the device meets the acceptance criteria, specifically related to AI in a clinical setting (e.g., sample size for test set, data provenance, expert ground truth, MRMC study, standalone performance, training set details), is not present in the provided text.

    The document discusses acceptance criteria and proof of mechanical performance and biocompatibility for the suture anchor. Here's what can be extracted based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance (Mechanical & Biocompatibility)

    Please note that the acceptance criteria are generally implied by the "Requirements" column and "Pass" result, indicating the device met those requirements. Specific numerical requirements are given where applicable.

    Anchor Performance

    Test ItemRequirementsReported Device Performance
    Insertion StrengthInsert each anchor with 5mm/min rate into 10pcf/40pcf combined urethane block.Pass
    Pull-out (FAS-1652802iw)Pull out each anchor with 5mm/min rate from 10pcf/40pcf combined urethane block.Pass
    Fatigue test (FAS-1652802iw)Pull out each anchor with 20N to 60N cycle loading and 1Hz/40,000 cycles from 10pcf/40pcf combined urethane block.Pass
    Pull-out (FAM-7615802fg)Pull out each anchor with 5mm/min rate from 10pcf/40pcf combined urethane block.Pass
    Fatigue test (FAM-7615802fg)Pull out each anchor with 20N to 60N cycle loading and 1Hz/40,000 cycles from 10pcf/40pcf combined urethane block.Pass

    Suture Performance (USP 0, UHMWPE)

    Test ItemRequirementsReported Device Performance
    AppearanceThe test article shall be no damage to the appearance in visual inspection.Pass
    LengthThe length of suture was measured while the strand is laid out smooth, without tension, on a plane surface: the length of the strand is not less than 95.0 percent of 750mm.Pass
    Tensile StrengthFor USP 0 size suture, tensile strength must be larger than 2.16 kgf.Pass
    Needle AttachmentFor USP 0 size suture, needle attachment must be larger than 1.50 kgf.Pass

    Suture Performance (USP 2, UHMWPE)

    Test ItemRequirementsReported Device Performance
    LengthThe length of suture was measured while the strand is laid out smooth, without tension, on a plane surface: the length of the strand is not less than 95.0 percent of 750mm.Pass
    Tensile StrengthFor USP 2 size suture, tensile strength must be larger than 3.52 kgf.Pass

    Suture Performance (USP 0, USP 2, UHMWPE)

    Test ItemRequirementsReported Device Performance
    AppearanceThe test article shall be no damage to the appearance in visual inspection.Pass
    DiameterFor USP 0 size suture, diameter must be within 0.350.399mm. For USP 2 size suture, diameter must be within 0.500.599mm.Pass
    Tensile strengthWith 25~35cm/min, record the load-displacement curves and maximum load. (N)Pass

    Biocompatibility (UHMWPE + PET)

    Test ItemTest Method / Test CriteriaReported Result
    CytotoxicityISO 10993-5, Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicityPass
    Systemic toxicity testISO 10993-11, Biological evaluation of medical devices - Part 11: Tests for systemic toxicityPass
    Pyrogen TestISO 10993-11 Test for systemic toxicity, pyrogen testPass
    Intracutaneous reactivity testISO 10993-10, Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitizationPass
    Maximization sensitizationISO 10993-10, Test for irritation and skin sensitization, Maximization test for delayed hypersensitivityPass
    Genotoxicity testISO 10993-3, Genotoxicity test OECE 471, Bacterial reverse mutation testPass
    Implantation testISO 10993-6, Tests for local effects after implantation, Annex D test methods for implantation in bonePass
    Hemolysis testISO 10993-4, Biological evaluation of medical devices - Part 4: Selection of tests for interactions with bloodPass
    Subchronic toxicityISO 10993-11 Tests for systemic toxicityPass

    Biocompatibility (Only UHMWPE)

    (Same tests and results as UHMWPE + PET table, excluding PET interaction)

    Test ItemTest Method / Test CriteriaReported Result
    CytotoxicityISO 10993-5, Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicityPass
    Systemic toxicity testISO 10993-11, Biological evaluation of medical devices - Part 11: Tests for systemic toxicityPass
    Pyrogen TestISO 10993-11 Test for systemic toxicity, pyrogen testPass
    Intracutaneous reactivity testISO 10993-10, Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitizationPass
    Maximization sensitizationISO 10993-10, Test for irritation and skin sensitization, Maximization test for delayed hypersensitivityPass
    Genotoxicity testISO 10993-3, Genotoxicity test OECE 471, Bacterial reverse mutation testPass
    Implantation testISO 10993-6, Tests for local effects after implantation, Annex D test methods for implantation in bonePass
    Hemolysis testISO 10993-4, Biological evaluation of medical devices - Part 4: Selection of tests for interactions with bloodPass
    Subchronic toxicityISO 10993-11 Tests for systemic toxicityPass

    Sterilization/Endotoxin

    Test ItemTest Method / Test CriteriaReported Result
    Endotoxin testUSP 43 <85>, Bacterial endotoxin test (LAL)Pass

    2. Sample size used for the test set and the data provenance:
    This information is not provided in the context of an AI/image-based diagnostic test set. The document refers to "bench tests" performed on physical samples of the anchors and sutures. The number of samples for each mechanical test is not specified, only that "each anchor" or "the test article" was evaluated. The data provenance is implied to be from AJU Pharm Co., Ltd.'s internal testing, likely at their facility or a contracted lab. No country of origin for this specific testing data is given, but the company address is in South Korea (A-207, 697, Pangyo-ro, Seongnam-si, Gyeonggi-do, Korea). The data is retrospective of the device design.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
    Not applicable for this type of device (mechanical and biocompatibility testing). Ground truth is established by objective physical measurements and standardized biological assays.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
    Not applicable for this type of device.

    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 not an AI-assisted diagnostic device.

    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 (expert consensus, pathology, outcomes data, etc):
    For mechanical tests: Physical measurements against engineering specifications (e.g., tensile strength, length, diameter, pull-out force).
    For biocompatibility tests: Standardized laboratory assays with pass/fail criteria based on ISO standards.
    For sterilization/endotoxin: Standardized laboratory assays (e.g., LAL test) with pass/fail criteria.

    8. The sample size for the training set:
    Not applicable. This is not a machine learning/AI device.

    9. How the ground truth for the training set was established:
    Not applicable.

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    K Number
    K192709
    Manufacturer
    Date Cleared
    2020-12-15

    (445 days)

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

    The non-absorbable suture anchors are intended to reattach soft tissue to bone in orthopedic surgical procedures. The Fixone All Suture Anchors may be used in either arthroscopic or open surgical procedures. After the suture strands are anchored to the bone, they may be used to reattach soft tissue, such as ligaments, tendons, or joint capsules to the bone. In conjunction with appropriate postoperative immobilization throughout the healing period, the suture anchor systems stabilize the damaged soft tissue.

    Device Description

    Fixone All suture anchor consists of one "fix Suture" and two or three non-absorbable Sutures. The nonabsorbable suture is manufactured from UHMWPE and PET fibers. Fixone All suture anchor is implanted using its self-punching option. They are pre-loaded on a handled insertion device is provided sterile, for single use only. This device is medical device. Prescription use only. This device is could used with instrument that manufactured by Aju Pharm Co.,Ltd. It is consist of 4 models. It provide non-sterile (user must sterilization before use).

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device called "Fixone All Suture Anchor." This document primarily focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than presenting a study proving that the device meets specific acceptance criteria for AI/ML performance.

    The document details bench testing for the physical device, including mechanical properties and biocompatibility, but does not describe an AI/ML-based device or a study involving AI/ML performance. Therefore, most of the requested information regarding AI/ML acceptance criteria, test sets, expert ground truth, MRMC studies, or AI algorithm-only performance cannot be extracted from this text.

    The "Performance data" section (Section 6) refers to laboratory bench tests for the physical product, not a study evaluating an AI/ML component.

    Therefore, I cannot provide the requested information regarding AI/ML validation studies from the given input.

    The document states:

    • Device: Fixone All Suture Anchor
    • Purpose: Reattach soft tissue to bone in orthopedic surgical procedures.
    • Nature of evidence provided for FDA clearance: Bench testing (mechanical and biocompatibility) comparing it to a predicate device (K133224, ConMed Corporation / Y-Knot RC All-Suture Anchor w/Two and Three #2).

    If this question was mistakenly associated with an AI/ML device, and the intent was to ask about the acceptance criteria and studies for this physical medical device, here's what can be inferred:


    Acceptance Criteria and Study for Fixone All Suture Anchor (Physical Medical Device)

    Based on the provided FDA 510(k) summary, the device is a physical suture anchor, not an AI/ML diagnostic or therapeutic device. The "acceptance criteria" here refer to demonstrating substantial equivalence through various bench tests.

    1. Table of Acceptance Criteria and Reported Device Performance

    Test ItemRequirements (Acceptance Criteria)Results (Reported Performance)
    Physical/Mechanical Tests
    SurfaceWhen examined by normal vision, the surface shall be free from defects.Pass
    Nominal size (Exclude suture)When tested by Vernier calipers, micrometer or tapeline, the measurement should be in accordance with standard.MD2018-00210 (Implies it met the standard)
    Insertion test (Comparison with predicate)Must perform in a substantially equivalent manner to the predicate device in 10pcf/40pfc Polyurethane block, self-punching, @ 90° implantation angle.Results provided (AJU_M, implying successful comparison with predicate "Yknot")
    Pull-out test (Comparison with predicate)Must perform in a substantially equivalent manner to the predicate device in 10pcf/40pfc Polyurethane block, self-punching, @ 90° pull-out angle with MTS Bionix servohydraulic tester.Results provided (D20201006_PT(Js, Yknot), implying successful comparison with predicate "Yknot")
    Fatigue test (Comparison with predicate)Must perform in a substantially equivalent manner to the predicate device in 10pcf/40pfc Polyurethane block, self-punching, with same cycle loading and rate.Results provided (Js, Yknot), implying successful comparison with predicate "Yknot")
    Biocompatibility Tests
    CytotoxicityISO 10993-5 (Tests for in vitro cytotoxicity)Pass
    Systemic toxicity testISO 10993-11 (Tests for systemic toxicity)Pass
    Pyrogen TestISO 10993-11 (Pyrogen test)Pass
    Intracutaneous reactivity testISO 10993-10 (Tests for irritation and skin sensitization)Pass
    Maximization sensitizationISO 10993-10 (Maximization test for delayed hypersensitivity)Pass
    Genotoxicity testISO 10993-3, OECD 471 (Bacterial reverse mutation test)Pass
    Implantation testISO 10993-6 (Tests for local effects after implantation, Annex D test for implantation in bone)Pass
    Hemolysis testISO 10993-4 (Selection of tests for interactions with blood)Pass
    Subchronic toxicityISO 10993-11 (Tests for systemic toxicity)Pass
    Sterilization & Packaging
    SterilizationISO 11135:2014 (Ethylene oxide sterilization requirements)ME-SVP-1802 (Implies meeting the standard)
    Shelf Life and PackagingISO11607-2 / EN 868-5 / ASTM F1980-16 / ASTM F88-15 / ASTM F1929:1998AJ-SL1702 (Implies meeting the standard)

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

    • Test Set Sample Size: For the mechanical tests (Insertion, Pull-out, Fatigue), the text explicitly states "10pcf/40pfc Polyurethane block." This refers to specific foam densities used for testing bone-like properties. While it mentions "10pcf/40pfc," it doesn't specify the number of samples (individual devices) tested for each condition. For biocompatibility tests, typically multiple replicates are used, but specific numbers are not provided.
    • Data Provenance: The tests were "Bench tests," meaning laboratory-based experimental data. No information about country of origin for the "data" itself, as it's not patient-derived data. The manufacturer is AJU Pharm Co., Ltd. from Korea.

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

    • Not applicable. This is for a physical device and involves objective measurements in a lab setting (e.g., force, dimensions, biological reactions based on ISO standards), not expert interpretation of complex data (like medical images).

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

    • Not applicable. Ground truth is established through standardized laboratory testing parameters and measurements, not subjective expert opinion requiring 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 is not an AI/ML device.

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

    • Not applicable. This is not an AI/ML device.

    7. The type of ground truth used:

    • "Ground truth" for this device is based on objective physical and chemical measurement standards and comparison to the established performance of a legally marketed predicate device. For instance, the ISO 10993 series for biocompatibility provides the "ground truth" criteria.

    8. The sample size for the training set:

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

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

    • Not applicable. This is not an AI/ML device.
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