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510(k) Data Aggregation

    K Number
    K180624
    Manufacturer
    Date Cleared
    2018-05-15

    (67 days)

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

    Guided Growth Plate System Plus

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

    The Guided Growth Plate System Plus is intended for redirecting the growth of long bones. It is indicated for gradually correcting angular growth deformities in growing children. Specific conditions/diseases for which the device will be indicated include: valgus, varus or flexion, extension deformities of the knee (femur and/or tibia); valgus, varus, or plantar flexion deformities of the ankle; valgus or varus deformities of the elbow (humerus), and radial or ulnar deviation, flexion or extension deformities of the wrist (radius).

    Device Description

    The Subject new 3.5mm thread diameter screw is a gamma extension of the existing screws (thread Ø4.5mm), components of the predicate Guided Growth Plate System Plus (K172183). The Subject device is a 3.5mm thread diameter screw, available in three lengths and manufactured by the same material (Ti6Al4V), as the 4.5mm diameter gamma screws, included in the predicate Guided Growth Plate System Plus (K172183).

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the "Guided Growth Plate System Plus" and a new 3.5mm thread diameter screw, which is an extension of the existing screws for the system. The submission focuses on demonstrating substantial equivalence to a predicate device (K172183) rather than proving the device meets acceptance criteria through a clinical study in the traditional sense of a diagnostic AI device.

    Therefore, many of the requested categories for AI/diagnostic device studies are not directly applicable. However, I can extract the relevant information regarding performance testing and how substantial equivalence was demonstrated.

    Here's a breakdown based on the information provided:

    1. Table of Acceptance Criteria and Reported Device Performance

    The submission is for a new screw size, so the "performance" is in demonstrating that this new size is as safe and effective as the existing screws within the Guided Growth Plate System Plus. The acceptance criteria relate to mechanical testing standards.

    Acceptance CriteriaReported Device Performance
    Mechanical Testing: Demonstrate mechanical integrity and safety of the 3.5mm thread diameter screw according to established standards.Testing activities met the established acceptance criteria, demonstrating that the device does not introduce additional risks compared to the predicate device. Specific standards followed: ASTM F564-17, ASTM F1264-16, ASTM F543-17.

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

    • Sample Size: Not explicitly stated regarding the number of screws or plates tested, but implies tests were conducted on the new 3.5mm thread diameter screws.
    • Data Provenance: The testing was mechanical, performed by the manufacturer, Orthofix Srl, in Italy. This is laboratory/bench testing, not patient data.

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

    • This is not applicable as the "ground truth" for mechanical testing is adherence to engineering standards and robust physical properties, not expert consensus on medical images or diagnoses.

    4. Adjudication Method for the Test Set

    • Not applicable for mechanical testing. The results are quantitative measurements against defined standards.

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

    • No. This is a hardware device (bone plate system components), not an AI/diagnostic software, so an MRMC study is not relevant.

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

    • Not applicable. This is a hardware device.

    7. The Type of Ground Truth Used

    • Mechanical Testing Standards: The "ground truth" for the performance data in this submission is the fulfillment of established engineering and material standards (ASTM F564, ASTM F1264, ASTM F543) for bone fixation devices and screws.
    • Clinical Literature Analysis: Supported by analysis of clinical literature to demonstrate clinical equivalence between the plate and screw system and staples (the reference devices).

    8. The Sample Size for the Training Set

    • Not applicable. This is a hardware device, not an AI model.

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

    • Not applicable. This is a hardware device.

    Additional Information from the document:

    • Device Description: The "Subject new 3.5mm thread diameter screw is a gamma extension of the existing screws (thread Ø4.5mm), components of the predicate Guided Growth Plate System Plus (K172183)." It is made of the same Ti6Al4V material.
    • Technological Characteristics & Substantial Equivalence: The submission claims substantial equivalence based on:
      • Indications for use
      • Intended patient population
      • System composition
      • Implant material
      • Method of fixation
      • Packaging configuration
      • Sterilization method
      • Biocompatibility
      • MRI compatibility
      • The only change is a design dimensional specification for the new 3.5mm thread diameter screw.
    • Biocompatibility Data: No additional assessment was required because the subject device is equivalent in material, manufacturing, sterilization, etc., to the predicate device (K172183).
    • Conclusion: The analysis of performance data (mechanical testing and clinical literature review) supports the conclusion that the new 3.5mm thread diameter screw is safe and effective and substantially equivalent to the predicate (K172183).
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    K Number
    K172183
    Manufacturer
    Date Cleared
    2018-01-09

    (174 days)

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

    Guided Growth Plate System Plus

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

    The Guided Growth Plate System Plus is intended for redirecting the growth of long bones. It is indicated for gradually correcting angular growth deformities in growing children. Specific conditions/diseases for which the device will be indicated include: valgus, varus or flexion, extension deformities of the knee (femur and/or tibia); valgus, varus, or plantar flexion deformities of the ankle; valgus or varus deformities of the elbow (humerus), and radial or ulnar deviation, flexion or extension deformities of the wrist (radius).

    Device Description

    The Guided Growth Plate System Plus is designed for the gradual correction of pediatric congenital as well as acquired deformities in both the upper and lower extremities, provided that the physis (growth plates) are not fused. It consists of different sizes of eight-Plate and quad-Plate plus with different cannulated and solid screw options. The plates feature a contoured waist and low profile for pediatric usage. There is a center hole in the plates for a temporary guide pin to be implanted, in order to aid application and removal of the plate. The plates are attached to the external surface of the bone by screws, which are not locked to the plate but rather they are allowed to swivel and diverge in their position as bone growth occurs. The implant acts like a flexible hinge, permitting growth at the growth plate to gradually straighten the limb.

    AI/ML Overview

    This document describes a medical device, the Guided Growth Plate System Plus, and its clearance through the FDA 510(k) pathway. This pathway establishes substantial equivalence to a predicate device rather than necessarily proving new efficacy. Therefore, the information provided focuses on demonstrating equivalence rather than establishing novel acceptance criteria and proving performance against them in the traditional sense of a clinical study.

    Here's a breakdown of the requested information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    As this is a 510(k) submission, the "acceptance criteria" are primarily related to demonstrating substantial equivalence to the predicate device and meeting applicable performance standards. There aren't specific quantitative accuracy metrics for a diagnostic device given here, but rather engineering and biocompatibility criteria.

    Acceptance Criterion (Category)Reported Device Performance / Assessment
    Mechanical Performance- The device was tested according to ASTM F564 – 10 "Standard Specification and Test Methods for Metallic Bone Staples."
    • "All testing met or exceeded the requirements, as established by the test protocols and applicable standard."
    • "A review of the mechanical data indicates that the components of the Subject device continues to be capable of withstanding expected loads without failure."
    • "The Subject device was therefore found to be substantially equivalent to the Predicate device and has the mechanical properties to perform its indications safely." |
      | Biocompatibility | - Tests performed on equivalent system devices according to USP 38:2014 "Bacterial endotoxin test (LAL)", USP 38:2014 "Medical devices – bacterial endotoxin and pyrogen tests", ANSI/AAMI ST72:2011 "Bacterial endotoxins - Test methodologies, routine monitoring and alternative batch testing", and FDA 2012 Q&A "Guidance for Industry Pyrogen and Endotoxins Testing: Question and Answers."
    • "to establish the Subject device non-pyrogenicity" |
      | Substantial Equivalence | - Demonstrated similarity to the predicate device (Guided Growth System Quad-Plate, K093442) in: intended use, indications for use, site of application, patient population, condition of use, technological characteristics, materials, mechanical performances, and implantable components. |
      | Design Improvements | - The subject device provides "design improvements and additional dimensions for implantable components, new sterile components and new related packaging configuration" while maintaining substantial equivalence. |
      | Risk Management | - "The potential hazards have been evaluated and controlled through a Risk Management Plan." |

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

    This document describes a medical device (surgical implant) and its review for substantial equivalence, not an AI/software as a medical device (SaMD) or diagnostic study with a "test set" of patient data in the typical sense.

    • Test Set Sample Size: Not applicable in the context of a clinical performance test set for an AI device. The "test set" for this device consists of the physical devices themselves and materials for mechanical and biocompatibility testing. No specific number of devices/materials tested is provided, but it's stated that "All testing met or exceeded the requirements."
    • Data Provenance: Not applicable for patient data. The provenance of the performance data (mechanical and biocompatibility) would be from in-vitro laboratory testing conducted by or for Orthofix Srl in Italy. The document mentions "test reports and rationale references list."

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

    Not applicable. This is not a study that requires expert adjudication for ground truth on clinical images or patient data. The "ground truth" for mechanical testing is defined by the standards (e.g., ASTM F564-10) and for biocompatibility by the international standards listed (e.g., USP 38, ANSI/AAMI ST72). These standards themselves are developed by expert consensus in their respective fields.

    4. Adjudication Method for the Test Set

    Not applicable. There is no clinical test set requiring adjudication in this 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. This is a physical medical device (guided growth plate) for surgical implantation, not an AI or imaging diagnostic device that would involve human readers or MRMC studies.

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

    Not applicable. This is not an algorithm or AI device.

    7. The Type of Ground Truth Used

    The "ground truth" for this device's performance evaluation is based on:

    • Engineering Standards: For mechanical performance (e.g., ASTM F564-10).
    • Biocompatibility Standards: For non-pyrogenicity (e.g., USP 38, ANSI/AAMI ST72).
    • Regulatory Substantial Equivalence Criteria: Comparing the device's characteristics to a legally marketed predicate device.

    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. As there is no training set, there is no ground truth to establish for one.

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