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510(k) Data Aggregation

    K Number
    K101030
    Manufacturer
    Date Cleared
    2010-06-03

    (51 days)

    Product Code
    Regulation Number
    888.3040
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    MODIFICATION TO HBS HEADLESS BONE SCREW

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use
    HBS-Mini (2.5mm)HBS Standard (3.0mm)
    Scaphoid fracturesScaphoid fractures
    Lunate fracturesCarpal fractures and non-unions
    CapitateCapitellum fractures
    Trapezial fracturesMetacarpal fractures
    Metacarpal and metatarsal fracturesPhalangeal fractures
    Phalangeal fracturesDistal radial fractures
    Radial head fracturesRadial head fractures
    Ulnar styloid fracturesUlnar styloid fractures
    Osteo-chondralSmall joint fusions
    Small joint fusionsHumeral head fractures
    Glenoid fractures
    Intercarpal fusions
    Interphalangeal fractures
    Metatarsal osteotomies
    Tarsal fusions
    Malleolar fractures
    Patellar fractures
    Osteo-chondral fractures
    Device Description

    The BioPro HBS screw is designed for hand, foot and small bone fragment repairs or fusions. Uses include osteotomy fixation, joint arthrodesis or post traumatic fragment repair. The BioPro HBS screw is made of titanium in compliance with ASTM F136-02a. The screw is similar to other screws available on the market. The HBS screw is cannulated and comes in two diameters, 2.5mm and 3.0mm. Each screw is available in several lengths ranging from 6mm up to 40mm in length. The screws have a Torx driving head. The new versions of the screw will be provided sterile.

    AI/ML Overview

    The provided text describes a 510(k) submission for a medical device (HBS Headless Bone Screw) and primarily focuses on proving substantial equivalence to a predicate device. It does not contain information about acceptance criteria or a study designed to prove the device meets specific performance metrics in the way that would typically be described for a diagnostic or AI-driven medical device.

    The "performance testing" mentioned refers to engineering rationale regarding the screw's material and design, particularly torsional strength, in relation to ASTM F-543 ("Standard Specification and Test Methods for Metallic Medical Bone Screw"). The primary "studies" described relate to sterilization validation.

    Therefore, many of the requested elements for describing acceptance criteria and a study cannot be directly extracted from the provided document.

    However, I can extract and interpret the information that is present regarding the device's characteristics and the rationale for its approval.

    Here's a breakdown based on the categories you provided, indicating where information is present versus not present:


    Acceptance Criteria and Device Performance Study (Based on Submitted Information)

    The document's primary "study" is a demonstration of substantial equivalence, with particular focus on the unchanged design (except for length), material, and sterilization process. It does not present specific quantitative performance metrics or acceptance criteria for clinical efficacy or diagnostic accuracy, as it is a bone screw and its performance is more related to mechanical properties and sterilization.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Implied)Reported Device Performance
    Material: Titanium ASTM F136-02a complianceDevice is made of Titanium ASTM F136-02a.
    Design: Cannulated with Torx drive, two diameters (2.5mm, 3.0mm)Design is identical to predicate device, with added lengths (up to 40mm).
    Torsional Strength: No change from predicate deviceEngineering rationale provided: diameters are unchanged, implying no change to torsional strength. (Specific values not provided)
    Sterility Assurance Level (SAL): 10^-6Sterility validated to 10^-6 SAL via Ethylene Oxide (EtO) using AAMI Overkill Method.
    EO and ECH Residuals: Compliance with ANSI/AAMI/ISO 10933-7EtO residuals testing protocol implemented as per standard (specific measured values not provided).
    Packaging: Compliance with medical packaging requirementsDouble blister system with Tyvek® Lids certified and tested per current requirements.

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

    • Sample Size for Test Set: Not applicable in the context of a clinical performance study as defined for AI or diagnostic devices. Performance is largely based on engineering testing and sterilization validation. Specific sample sizes for engineering tests (e.g., how many screws tested for torsional strength, or how many sterilization cycles validated) are not provided in this summary.
    • Data Provenance: Not applicable in the context of clinical data for software. The "data" pertains to engineering specifications, material compliance, and sterilization validation results, which would be generated internally from laboratory testing.

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

    • Not applicable. "Ground truth" in this context would relate to objective measurements of mechanical properties or sterility, not expert interpretation of clinical data.

    4. Adjudication Method for the Test Set

    • Not applicable.

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

    • No. This is a medical device (bone screw), not a diagnostic tool or AI software. Therefore, 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 physical medical device, not an algorithm.

    7. The Type of Ground Truth Used

    • Engineering Specifications: Compliance with ASTM F136-02a for material and, by engineering rationale, maintenance of torsional strength based on unchanged diameter.
    • Sterilization Validation Standards: Compliance with ANSI/AAMI/ISO 10933-7 and ANSI/AAMI ST 27-1988 for sterility assurance and residuals.
    • Predicate Device Equivalence: The ultimate "ground truth" for the 510(k) submission is demonstrating substantial equivalence to the legally marketed predicate device (K020791 for the original design, and K991197 for additional lengths) in terms of safety and effectiveness, given the minor modifications (sterilization and increased length).

    8. The Sample Size for the Training Set

    • Not applicable. This is not an AI or machine learning device requiring a training set.

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

    • Not applicable.

    Summary of the Study that Proves the Device Meets Acceptance Criteria:

    The "study" described in the 510(k) summary is not a single, comprehensive clinical trial for performance metrics typical of AI or diagnostic devices. Instead, it comprises several components:

    • Engineering Rationale: An engineering rationale was provided to demonstrate that because the screw diameters remain unchanged, there is no change to the torsional strength from the predicate device, which is made of the same ASTM-compliant titanium (F136-02a). This addresses the mechanical performance aspect.
    • Sterilization Validation Study: A complete summary of studies related to sterilization (Attachment "B" of the submission) was included. This validation was performed using the Ethylene Oxide (EtO) method with an AAMI Overkill Method to achieve a Sterility Assurance Level (SAL) of 10^-6. EtO and ECH residuals were tested to meet ANSI/AAMI/ISO 10933-7 standards.
    • Packaging Validation: Packaging (double blister system with Tyvek® Lids) was certified and tested according to current medical packaging requirements.
    • Risk Analysis: A complete risk analysis for sterilization and packaging (Attachment "A" of the submission) was provided.
    • Device Comparison: A tabular comparison highlighting the similarities in material and design, and the modifications (sterilization, length increase) relative to predicate devices (Vilex 510k 991197, Osteomed K010783, and the original HBS 510k 020791).

    The conclusion of the submission states that "Based on these studies we believe the subject device is safe and effective" and that the device is "substantially equivalent to the predicate devices" due to the unchanged design (except for length), material, and new sterilization. The FDA's 510(k) clearance (K101030) confirmed this substantial equivalence.

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