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510(k) Data Aggregation
(57 days)
PALACOS MV pro
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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