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510(k) Data Aggregation
(57 days)
PALACOS® MV pro is indicated for use in arthroplastic procedures of the hip, knee, and other joints for the fixation of polymer or metallic prosthetic implants to living bone.
PALACOS® MV pro is a standard-setting, medium viscosity, radiopaque, poly(methyl methacrylate)-based (PMMA) bone cement, pre-filled into a mixing and application system, suitable for use with or without vacuum (ready to mix). It contains the X-ray contrast medium zirconium dioxide. To improve visibility in the surgical field, it has been colored with chlorophyllcopper-complex (E141). The bone cement consists of two components and is prepared immediately before use by mixing the polymer powder) with the monomer liquid (= liquid). A ductile dough forms that sets within a few minutes.
The provided text describes a 510(k) premarket notification for a medical device called PALACOS® MV pro, a polymethylmethacrylate (PMMA) bone cement. This submission aims to demonstrate substantial equivalence to a legally marketed predicate device.
The information provided does not describe the acceptance criteria and the study that proves the device meets the acceptance criteria in the context of an AI/ML powered device, or any diagnostic device subject to performance metrics like sensitivity, specificity, AUC, etc. Instead, it focuses on demonstrating substantial equivalence to a predicate device, which is a different regulatory pathway.
Therefore, many of the requested items (e.g., performance metrics, sample sizes for test/training sets, expert qualifications, adjudication methods, MRMC studies, standalone performance) are not applicable or mentioned in this document.
Here's an analysis based on the information provided in the document:
1. A table of acceptance criteria and the reported device performance:
The document doesn't explicitly state acceptance criteria in terms of specific numerical thresholds for performance metrics commonly associated with AI/ML or diagnostic devices (e.g., sensitivity, specificity, AUC). Instead, the "acceptance criteria" for demonstrating substantial equivalence are based on matching the predicate device's intended use, technological characteristics, and operating principle. The "reported device performance" is demonstrated through various tests designed to show that the subject device functions as intended and is safe and effective, aligning with the predicate.
| Acceptance Criteria Category (Implied by SE) | Reported Device "Performance" (Meeting Criteria) |
|---|---|
| Intended Use | PALACOS® MV pro has the same intended use as the predicate (PALACOS® R pro, K210607): fixation of polymer or metallic prosthetic implants to living bone in arthroplastic procedures of the hip, knee, and other joints. |
| Technological Characteristics (Device Design, Material, Operating Principle) | Both devices are PMMA bone cements, consist of two pre-filled components, and are prepared immediately before use by mixing polymer powder with monomer liquid. |
| Chemical Composition | The subject and predicate devices share the same chemical composition at a high level. |
| Sterilization Method | Both are sterilized with ethylene oxide as per DIN EN ISO 11135 and DIN EN ISO 10993-7. The sterilization process for PALACOS® MV pro was validated according to ISO 11135 to achieve an SAL of 10^-6. |
| Mechanical Characteristics | Mechanical testing performed according to ISO 5833 and ASTM F451 demonstrated equivalence to the predicate. |
| Mixing and Application Properties | These properties were considered equivalent to the predicate. |
| Clinical Use, Anatomical Location, Duration of Exposure, Intended Use Population | These aspects are equivalent to the predicate device. |
| Biocompatibility | Evaluations (Cytotoxicity, Sensitization, Irritation, Acute Systemic Toxicity, Material-mediated Pyrogenicity, Genotoxicity, Hemocompatibility, Implantation) were performed on a representative device (PALACOS® R, K202475) and deemed applicable due to identical qualitative components and minor quantitative differences not altering chemical/physical properties. Additionally, cytotoxicity testing was performed on PALACOS® MV pro and PALACOS® R pro. |
| Pyrogenicity | PALACOS® MV pro was tested for bacterial endotoxins using the LAL test (ANSI/AAMI ST72) and meets the specification of ≤ 20 EU/device, showing equivalence to the predicate. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
- Test Set Sample Size: Not applicable in the context of an AI/ML test set. The document refers to various engineering and biological tests conducted on the device itself or representative materials. The 'sample size' for these tests would refer to the number of units tested, but this is not specified for each test.
- Data Provenance: Not applicable in the context of an AI/ML test set. The tests are laboratory-based and follow international standards. The manufacturer is Heraeus Medical GmbH, located in Germany.
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 is not a diagnostic device or an AI/ML system requiring expert-established ground truth for a test set. The "ground truth" for this device's performance is established through adherence to recognized international standards and laboratory testing for physical, mechanical, chemical, and biological properties.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
Not applicable. There is no expert adjudication process described, as it's not relevant for this type of device and 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 bone cement, not an AI-assisted diagnostic tool. No MRMC study was performed or is relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
Not applicable. This is a PMMA bone cement, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
The "ground truth" for this device's safety and effectiveness, in the context of substantial equivalence, is rooted in:
- International Standards: Adherence to established mechanical (ISO 5833, ASTM F451), sterilization (ISO 11135), biocompatibility (ISO 10993-1), and pyrogenicity (ANSI/AAMI ST72) standards.
- Predicate Device Performance: The demonstrated safe and effective use of the predicate device (PALACOS® R pro) acts as a benchmark. The subject device is shown to be equivalent in its properties to this predicate.
- Laboratory Testing Results: Direct measurements of physical, chemical, and biological properties in controlled laboratory settings.
8. The sample size for the training set:
Not applicable. This is not an AI/ML device, so there is no "training set."
9. How the ground truth for the training set was established:
Not applicable. There is no "training set" or associated ground truth establishment process for this device as it is not an AI/ML product.
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(27 days)
PALACOS ® MV is intended for use in arthroplastic procedures of the hip, knee, and other joints for the fixation of polymer or metallic prosthetic implants to living bone.
PALACOS® MV is an acrylic bone cement for use in orthopedic surgery. It is formed from powder and liquid by exothermic polymerization. It secures the fixation of the grafted artificial joint, improving the transfer of forces at the interface implant - bone. It is currently marketed in a 44 g packaging size in the United States.
The provided document is a 510(k) summary for a medical device called PALACOS® MV, which is a polymethylmethacrylate (PMMA) bone cement. This document details the device's characteristics and its substantial equivalence to a predicate device, but does not describe "acceptance criteria" or a "study that proves the device meets the acceptance criteria" in the context of an AI/ML medical device.
The information requested in the prompt (acceptance criteria, study details, sample sizes, ground truth establishment, expert qualifications, adjudication methods, MRMC studies, standalone performance, training set details) is typically associated with the rigorous validation of AI/ML-based medical devices for regulatory clearance. Since PALACOS® MV is a physical bone cement, these types of evaluations are not applicable.
Instead, the document focuses on demonstrating the substantial equivalence of PALACOS® MV to a previously cleared predicate device (Palamed®, K030904) through preclinical testing of its physical and mechanical properties. The "acceptance criteria" in this context would refer to the standards outlined in ISO 5833 and Heraeus's internal final test requirements, which the device met.
Here's an attempt to answer the questions based on the provided text, while highlighting the irrelevance of some questions to this type of device:
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A table of acceptance criteria and the reported device performance
Acceptance Criteria (Standards Met) Reported Device Performance (PALACOS® MV) ISO 5833 Doughing time, maximum temperature, setting time, intrusion, compressive strength, bending modulus, and 4-point bending strength were characterized. Met ISO 5833 standards. Heraeus final test requirements Tested for impact and bending strength (Dynstat test method). Met Heraeus final test requirements. ANSI/AAMI ST72:2011 (Bacterial Endotoxin Test) Bacterial endotoxin evaluated (LAL test). Test results met endotoxin limits (20 endotoxin units (EU)/Device). Stability/Shelf Life Data compared between subject and predicate devices. No specific quantitative criteria or results are detailed beyond "data were also compared". -
Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document does not explicitly state the sample sizes for the preclinical tests conducted to characterize the physical and mechanical properties of the bone cement. The tests were presumably conducted in a laboratory setting, likely in Germany, where Heraeus Medical GmbH is located. This would be considered prospective controlled laboratory testing, not data provenance in the AI/ML sense.
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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. "Ground truth" in the context of expert consensus (e.g., for image interpretation) is not relevant for evaluating the physical properties of bone cement. The "ground truth" for bone cement performance is based on established engineering and materials science principles, and international standards (like ISO 5833).
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Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. Adjudication methods are used to resolve disagreements among human reviewers of data, particularly in complex medical image interpretation or clinical outcomes. This is not
relevant for standardized mechanical and chemical testing of a material. -
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. MRMC studies are used to evaluate the impact of an AI algorithm on human reader performance, typically in diagnostic tasks. This device is a physical bone cement, not an AI/ML algorithm, so an MRMC study was not performed.
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If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. The concept of "standalone performance" refers to the evaluation of an AI algorithm independent of human interaction. PALACOS® MV is a physical product. Its performance is evaluated through material science tests, not as an algorithm.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for the performance of PALACOS® MV is based on objective measurements and established international standards for bone cement (e.g., ISO 5833) and bacterial endotoxin testing (ANSI/AAMI ST72:2011). This is material science and chemistry, not clinical "outcomes data" or "pathology" in the diagnostic sense.
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The sample size for the training set
Not applicable. As a physical product, there is no "training set" in the context of AI/ML. The device's properties are inherent to its formulation and manufacturing process, evaluated through testing.
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How the ground truth for the training set was established
Not applicable, as there is no "training set" for this device.
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