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510(k) Data Aggregation

    K Number
    K190811
    Manufacturer
    Date Cleared
    2019-11-27

    (243 days)

    Product Code
    Regulation Number
    882.5320
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Optimus NEURO System - Sterile Kit

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

    The Optimus Neuro Plating System is intended for use in selective trauma of the cranial skeleton, cranial surgery and reconstructive procedures.

    Device Description

    The Neuro Plating System is comprised of plates and screws. The range of plate sizes is from 0.3mm to 0.6mm thick. It is made of commercially pure titanium of Gr 1, 2 and 3 (ASTM F67) and comes in 3 anodized colors (silver, blue and gold). The screws range in diameter from 0.8mm to 1.95mm and in lengths of 3.0mm to 6.0mm. They are made of Ti- 6Al-4V ELI titanium alloy (ASTM F136) and come in 3 anodized colors (silver, green and gold).

    The Neuro Plating System consists of plates and screws to provide fixation and aid in the alignment and stabilization of fractures in the reconstructive process. The plate is placed on the fractured bone and the screw is inserted into the bone through a plate hole to achieve fixation. If necessary, the plate may be bent or cut to meet the anatomical needs of the patient.

    The Neuro Plating System has two types of sterilization methods: 1.) the Neuro Plating System is non-sterile state packed in a PE bag which must be sterilized before use; and 2.) the Neuro Plating System - Sterile Kit is provided sterile using gamma sterilization packed in Tyvek and PET. Both are single use only.

    AI/ML Overview

    The provided text describes the regulatory clearance of a medical device, the Optimus Neuro Plating System, and details its substantial equivalence to predicate devices. It does not present a study proving the device meets specific acceptance criteria in terms of AI or algorithm performance.

    The "acceptance criteria" and "study that proves the device meets the acceptance criteria" in this document refer to regulatory acceptance for market clearance based on substantial equivalence to existing devices, rather than performance metrics for an AI-powered system or diagnostic accuracy study.

    Therefore, many of the requested items (e.g., sample size for test set, number of experts for ground truth, MRMC study, standalone algorithm performance) are not applicable to this type of submission.

    Here's how the provided information relates to your request:

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

    The document doesn't present "acceptance criteria" in the sense of performance metrics for an AI system. Instead, it presents a comparison table demonstrating the "substantial equivalence" of the modified device to its predicate devices across various attributes. The "performance" here refers to the device proving it is as safe and effective as the predicate, not a quantifiable clinical outcome or AI accuracy.

    Table: Comparison of Modified Device to Predicate Devices for Substantial Equivalence

    Feature/CriterionModified Device (Optimus Neuro Plating System) Performance/DescriptionUnmodified (Predicate) Device (K141911) Performance/DescriptionUnmodified (Predicate) Device (K183352) Performance/DescriptionEquivalence Outcome / "Acceptance"
    ManufacturerOSTEONIC Co., Ltd.OSTEONIC Co., Ltd.OSTEONIC Co., Ltd.-
    Device NameNEURO PLATING SYSTEMNEURO PLATING SYSTEMNEURO PLATING SYSTEM-
    510(K) #K190811K141911K183352-
    Class222Equivalent
    Product CodeGWO, GRX, HBWGWO, GRX, HBWGWO, GRX, HBWEquivalent
    Intended UseIntended for use in selective trauma of the cranial skeleton, cranial surgery and reconstructive procedures.Intended for use in selective trauma of the cranial skeleton, cranial surgery and reconstructive procedures.Intended for use in selective trauma of the cranial skeleton, cranial surgery and reconstructive procedures.Equivalent
    Material (Chemical Composition)Plate: Pure Titanium ASTM F67; Screw: Titanium Alloy ASTM F136Plate: Pure Titanium ASTM F67; Screw: Titanium Alloy ASTM F136Plate: Pure Titanium ASTM F67; Screw: Titanium Alloy ASTM F136Equivalent
    Surface TreatmentPlate: Anodized; Screw: AnodizedPlate: Anodized; Screw: AnodizedPlate: Anodized; Screw: AnodizedEquivalent
    Shape and DimensionStraight, burr hole with various lengths and thickness. Plate sizes: 0.3mm to 0.6mm thick. Screw diameter: 0.8mm to 1.95mm; lengths: 3.0mm to 6.0mm.Straight, angle, Y-shape, X-shape, burr hole, square, matrix and mesh with various lengths and thickness. Plate: various length and thickness (0.1 to 0.6mm). Screw diameter: 0.8 to 1.8mm; lengths: 3.0 to 6.0mm.D-Y Shape, Y-Shape, Burr hole Plate and mesh with various lengths and thickness (0.3 to 0.6mm).Plates and screws were found to be substantially equivalent through 4 point bending testing, torsional testing, and axial pullout strength testing. The modified devices passed all testing.
    Single UseYESYESYESEquivalent
    SterileNeuro Plating System: Non sterile, steam sterilization before use. Neuro Plating System Sterile Kit: sterile, gamma irradiation.Non sterile, steam sterilization before use.Non sterile, steam sterilization before use.Neuro Plating System - Sterile Kit (gamma irradiation) added. Plates and screws were evaluated through packaging process validation test, gamma sterilization validation and shelf life. The modified devices passed all testing.
    Non-clinical tests performed on modified device4 Point Bending Test, Torsion Test & Axial Pullout Strength Test, Packaging Process Validation Test (Sterile Kit only), Gamma Sterilization Validation (Sterile Kit only), Shelf life (Sterile Kit only), MR safety test. Test results demonstrated that the subject devices are substantially equivalent to the predicate devices.Testing on predicate devices, by which the modified device was compared for substantial equivalence.Testing on predicate devices, by which the modified device was compared for substantial equivalence."Test results demonstrated that the subject devices are substantially equivalent to the predicate devices." "overall higher than the predicate devices" (for some mechanical tests)

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

    • Test Set Description: The "test set" in this context refers to the samples of the physical device that underwent non-clinical laboratory testing (e.g., mechanical strength, sterilization validation).
    • Sample Size: The document does not specify the exact number of units used for each test (e.g., how many plates/screws for the 4-point bending test). It only states that "The following tests were performed on the modified devices."
    • Data Provenance: The tests were performed by Osteonic Co., Ltd. (the manufacturer) in South Korea. The data would be internally generated "non-clinical tests." The provenance typically refers to the source of the clinical data (e.g., patient records), which is not relevant here as this is a device clearance based on engineering and material testing. The tests are prospective as they were conducted for this submission.

    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):

    • Not applicable. This submission is for a physical medical implant, not an AI or diagnostic imaging device that requires interpretation by medical experts to establish ground truth for performance evaluation. The "ground truth" for the device's characteristics (e.g., material strength, sterility) is established by standardized engineering tests and established quality control methods, not expert consensus on medical images.

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

    • Not applicable. This refers to a method used to resolve discrepancies in expert interpretations (e.g., for image annotations or diagnoses), which is not relevant to the non-clinical engineering and material tests performed for this 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 a type of study performed for diagnostic AI tools to evaluate their impact on human interpretation. This submission is for a physical neuro plating system.

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

    • Not applicable. This describes the performance evaluation of an AI algorithm in isolation. The Optimus Neuro Plating System is a physical implant, not an algorithm.

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

    • For the physical device, the "ground truth" for demonstrating substantial equivalence is based on:
      • Engineering specifications and standards: ASTM F67, ASTM F136, ISO 10993.
      • Validated test methods: 4 Point Bending Test, Torsion Test, Axial Pullout Strength Test, Packaging Process Validation Test, Gamma Sterilization Validation, Shelf life, MR safety tests.
      • Comparison to predicate device performance data in these established physical and biological safety metrics.

    8. The sample size for the training set:

    • Not applicable. This is relevant for AI/ML models. This document describes a physical medical device.

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

    • Not applicable. Relevant for AI/ML models.
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    K Number
    K183352
    Manufacturer
    Date Cleared
    2019-01-02

    (30 days)

    Product Code
    Regulation Number
    882.5320
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Optimus Neuro System

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

    Optimus Neuro System is intended for use in selective trauma of the cranial surgery and reconstructive procedure.

    Device Description

    The Optimus NEURO System is comprised of plates and screws. The range of plate sizes is from 0.3mm to 0.6mm thick. It is made of commercially pure titanium of Gr 1, 2 and 3 (ASTM F67) and in 3colors (silver, blue and gold) by anodizing. The range of screw diameter is from 0.8mm to 1.8mm in lengths of 3.0 to 6.0mm. It is made of Ti-6AI-4V ELI titanium alloy (ASTM F136) and in 3 colors (silver, green and gold) by anodizing.

    The device is packed separately in a PE bag. The plate and screw are single use only, non-sterile products. The devices must be sterilized before use.

    Optimus NEURO System consists of plates and screws to provide fixation and aid in the alignment and stabilization of fractures in reconstructive processes. The placed on the fractured bone and the screw is inserted into the bone through a plate hole to fix. If necessary, the plate may be bent or cut to meet the anatomical needs of patient

    AI/ML Overview

    This document describes the Optimus Neuro System, a device intended for use in cranial surgery and reconstructive procedures. It's important to note that this submission focuses on the device itself (plates and screws), not an AI algorithm. Therefore, many of the requested AI-specific details are not applicable.

    Here's an analysis based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Criterion (Type of Test)Acceptance Criteria (Implied)Reported Device Performance
    4 Point Bending TestSubject device performance should be comparable or superior to the predicate device."The test results of the subject device were overall higher than the predicate devices..."
    Packaging Process Validation TestPackaging must ensure device integrity and sterility until use.Test performed, implied successful.
    Sterilization Parameters ValidationDevice must be able to be effectively sterilized.Supported by primary predicate K141911.
    BiocompatibilityDevice materials must be biocompatible.Supported by primary predicate K141911.
    Functional EquivalenceDifferences in shape and dimensions should not raise new issues in safety and performance."performance test data provided in this submission proves that this differences do not raise new issues in safety and performance."

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

    The document does not explicitly state the sample sizes used for the "4 Point Bending Test" or "Packaging Process Validation Test." It refers to "the subject device and the predicate devices," suggesting that a sufficient number of units were tested to draw conclusions.

    • Data Provenance: The manufacturing company, Osteonic Co., Ltd., is based in Seoul, Korea. The tests were likely conducted in a controlled lab environment. The study is retrospective in the sense that it's comparing a modified device to an existing predicate, and the testing isn't on human subjects for clinical outcomes, but rather on the physical properties of the device.

    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 this is a submission for a medical device (plates and screws), not an AI algorithm requiring expert ground truth for image or data interpretation. The "ground truth" here is based on engineering standards and physical test results.

    4. Adjudication Method for the Test Set

    This is not applicable as it pertains to expert disagreement in AI-driven diagnostic tasks, which is not relevant to this device's testing.

    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

    This is not applicable as this is a medical device (plates and screws), not an AI algorithm.

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

    This is not applicable as this is a medical device (plates and screws), not an AI algorithm.

    7. The Type of Ground Truth Used

    The "ground truth" for this device's performance is established by:

    • Engineering Standards: Adherence to material specifications (ASTM F67, ASTM F136) and performance standards (e.g., implied stress/strain limits for the 4-point bending test).
    • Physical Test Results: Direct measurements of mechanical properties (bending strength) and packaging integrity.
    • Previous Validation Data: Relying on sterilization and biocompatibility data from the primary predicate device (K141911).

    8. The Sample Size for the Training Set

    This is not applicable as this is a medical device (plates and screws) and does not involve AI or machine learning models that require a training set.

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

    This is not applicable for the same reasons as above.

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    K Number
    K141911
    Manufacturer
    Date Cleared
    2015-02-10

    (210 days)

    Product Code
    Regulation Number
    882.5320
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    OPTIMUS NEURO SYSTEM

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

    Optimus Neuro System is intended for use in selective trauma of the cranial skeleton, cranial surgery and reconstructive procedure.

    Device Description

    The Optimus Neuro System is comprised of plates and screws. The range of plate sizes is from 0.3mm to 0.6mm thick. It is made of commercially pure titanium of Gr 1, 2 and 3 (ASTM F67) and in 3 colors (silver, blue and gold) by anodizing. The range of screw diameter is from 0.8mm to 1.8mm in lengths of 3.0 to 6.0mm. It is made of Ti-6AI-4V ELI titanium alloy (ASTM F136) and in 3 colors (silver, greenand gold) by anodizing. The plate and screw are a single use only, non-sterile product and they must be sterilized by the user before use. Each component is individually packed in a PE bag. Optimus NEURO System consists of plates and screws to provide fixation and aid in the alignment and stabilization of fractures in reconstructive processes. The placed on the fractured bone and the screw is inserted into the bone through a plate hole to fix. If necessary, the plate may be bent or cut to meet the anatomical needs of patient.

    AI/ML Overview

    The provided text describes the "Optimus Neuro System," a medical device for cranial surgery and reconstructive procedures. However, the document primarily focuses on demonstrating substantial equivalence to predicate devices through bench testing (mechanical, sterilization, cleaning, and packaging validation), rather than a clinical study involving human or animal subjects that would typically involve acceptance criteria for diagnostic or clinical performance.

    Therefore, the information required to directly answer some of your questions, particularly those related to a study proving diagnostic or clinical performance (e.g., sample size for test set, number of experts, adjudication methods, MRMC studies, standalone performance, training set details), is not present in this document. This is common for devices like cranioplasty plates and screws, where substantial equivalence is often established through material testing, mechanical performance, and comparisons to existing devices with a long history of safe and effective use.

    Here's a breakdown of what can be answered based on the provided text:


    1. Table of Acceptance Criteria and Reported Device Performance

    TestAcceptance Criteria (Implied)Reported Device Performance
    Sterilization Validation TestSterility assurance level (SAL) of 10⁻⁶ for steam sterilization.Sterility assurance level (10⁻⁶) for the recommended steam sterilization parameters is met.
    Mechanical TestPre-set criteria for mechanical characteristics (not specified).Worst case test articles have passed the pre-set criteria. The subject devices have been validated in mechanical characteristics.
    Cleaning Process ValidationBioburden level and endotoxin criteria of 2.15 EU/device.The subject devices showed low bioburden level and met criteria of 2.15 EU/device for endotoxin. The cleaning process at the manufacturing sites has been validated.
    Packaging Validation TestComplete sealing of final packaging.Final packaging of the subject device has passed the testing for its complete sealing. The subject device will be well protected until use in its packaging.

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

    • Sample Size (Test Set): Not specified. The document refers to "worst case test articles" for mechanical testing, implying a limited number of samples were tested for each specified test type. These are bench tests on physical devices, not a clinical study on patient data.
    • Data Provenance: Not applicable in the context of a clinical test set. The tests described are laboratory/bench tests on manufactured devices, not patient data.

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

    • Not applicable. The ground truth for bench testing is established by technical specifications and validated test methods, not expert clinical consensus.

    4. Adjudication method for the test set

    • Not applicable. This is not a clinical study with image interpretation or similar expert-dependent outcomes.

    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 device is a mechanical implant (plates and screws), not an AI-powered diagnostic or assistive tool for human readers.

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

    • Not applicable. This device is a mechanical implant, not an algorithm. Performance relates to its physical and material properties.

    7. The type of ground truth used

    • For the bench tests, the ground truth or reference standard is based on pre-set criteria, technical specifications, and recognized standards (e.g., ASTM F67, ASTM F136 for materials, and established parameters for sterilization, bioburden, and packaging integrity).

    8. The sample size for the training set

    • Not applicable. This device does not involve a "training set" in the context of machine learning or algorithms.

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

    • Not applicable. As above, this is a mechanical device, not an AI model.

    Summary of Study Type:

    The "study" described in the provided text is a set of non-clinical bench tests and validation activities, typical for demonstrating the safety and performance of medical implants like cranioplasty plates and screws. These tests are designed to confirm material properties, mechanical strength, sterility, cleanliness, and packaging integrity, which are crucial for the intended use of such a device in surgery. The objective is to demonstrate substantial equivalence to already legally marketed predicate devices, primarily through engineering and material science evaluations, rather than clinical efficacy studies on patient outcomes or diagnostic accuracy.

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