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510(k) Data Aggregation

    K Number
    K163650
    Date Cleared
    2017-04-24

    (122 days)

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

    ORTHOLOC**®** 3Di Ankle Fusion Plating System Line Extension

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

    The ORTHOLOC® 3Di Ankle Fusion Plating System is intended to facilitate arthrodesis of the ankle including tibiotalocalcaneal and tibiotalar joints and tibiocalcaneal arthrodessis, in conjuction with osteotomies of the distal tibia, talus, and calcaneus.

    ORTHOLOC® Bone Screws are indicated for use in bone reconstruction, osteotomy, arthrodesis, joint fusion, fracture repair, and fracture fixation, appropriate for the size of the device.

    Device Description

    The subject Universal Anterior Plate is designed to facilitate arthrodesis of the ankle and is composed of titanium alloy. The plate features poly-axial locking screw holes and one compression slot. It accepts screws of multiple diameters and lengths.

    AI/ML Overview

    The provided text is a U.S. FDA 510(k) premarket notification document for a medical device. This type of document is a submission to the FDA to demonstrate that the device to be marketed is at least as safe and effective as a legally marketed predicate device.

    The document does not describe the acceptance criteria or a study proving the device meets acceptance criteria in the way typically expected for an AI/ML device or a diagnostic device. It is for a mechanical orthopedic implant (an ankle fusion plating system).

    The "study" referenced in this document is a "non-clinical" engineering analysis (Finite Element Analysis and cross-sectional analysis) rather than a clinical trial or performance study against specific acceptance criteria for diagnostic output.

    Therefore, most of the information requested in your prompt (e.g., sample size for test/training sets, data provenance, number/qualifications of experts, ground truth, MRMC study, standalone performance) is not applicable or not present in this document because it pertains to a different type of medical device evaluation.

    However, I can extract the relevant information from the document as best as possible, focusing on how substantial equivalence was demonstrated:


    1. Table of Acceptance Criteria and Reported Device Performance

    For this orthopedic implant, the "acceptance criteria" are implied by the demonstration of "substantial equivalence" to a predicate device in terms of mechanical performance. The study aimed to show that the new device's bending strength was comparable to the predicate and did not introduce a new worst-case scenario.

    Acceptance Criteria (Implied)Reported Device Performance
    Bending strength comparable to predicate deviceDemonstrated substantial equivalence in bending strength to the predicate.
    No new worst-case scenario introduced compared to the predicate.Did not introduce a new worst case into the system.

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

    • Sample Size: Not applicable. The "test" here refers to non-clinical engineering analysis (Finite Element Analysis and cross-sectional analysis), not a traditional clinical sample size or dataset for diagnostic performance.
    • Data Provenance: Not applicable. As an engineering analysis, it relies on material properties, design specifications, and computational models, not patient data from a specific country or retrospective/prospective studies.

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

    Not applicable. Ground truth, in the context of diagnostic performance, is not relevant for this mechanical engineering analysis.

    4. Adjudication Method for the Test Set

    Not applicable. This is not a study involving human readers or interpretation requiring adjudication.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

    No, an MRMC comparative effectiveness study was not done. This device is a mechanical implant, not a diagnostic tool evaluated by human readers.

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

    Not applicable. This is a mechanical device, not an algorithm.

    7. The type of ground truth used

    Not applicable. For a mechanical device evaluated through engineering analysis, "ground truth" as typically understood in diagnostic studies (e.g., pathology, outcomes data, expert consensus) is not applied. The "truth" is established by the laws of physics and engineering principles applied in the analysis.

    8. The Sample Size for the Training Set

    Not applicable. There is no "training set" as this is a mechanical device evaluated through engineering analysis, not an AI/ML algorithm.

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

    Not applicable. There is no "training set" or "ground truth" in the context of an engineering analysis for a mechanical device.


    Summary of the Study for Substantial Equivalence:

    The study performed was a non-clinical evaluation consisting of:

    • Finite Element Analysis (FEA)
    • Cross-sectional analysis

    These analyses were conducted to compare the bending strength of the new ORTHOLOC® 3Di Universal Anterior Plate to its predicate device (K121425: ORTHOLOC® 3Di Ankle Fusion Plating System). The conclusion was that the new plate demonstrated substantial equivalence in bending strength and did not introduce a new worst-case scenario into the system. This type of evaluation is standard for demonstrating the safety and effectiveness of mechanical orthopedic implants for 510(k) clearance, rather than the clinical performance studies typically required for AI/ML or diagnostic devices.

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