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510(k) Data Aggregation

    K Number
    K221502
    Date Cleared
    2022-07-26

    (64 days)

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

    Parcus Synd-EZ SS

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

    The Parcus Synd-EZ SS is intended to be used as an adjunct in fracture repair involving metaphyseal and periarticular small bone fragments where screws are not indicated, and as adjuncts in external and intramedullary fixation systems involving plates and rods, with fracture braces and casting.

    The Parcus Synd-EZ SS is intended to provide fixation during the healing process following syndesmotic trauma, such as fixation of the syndesmosis (syndesmosis disruptions) in connection with Weber B and Weber C ankle fractures.

    Device Description

    The Parcus Synd-EZ SS consists of two buttons with suture connecting them and are designed to be used for stabilizing the syndesmosis during healing. Building upon the technology of the Parcus Synd-EZ Ti, the Synd-EZ SS is easily adjusted for length and resists elongation without requiring knots to secure the fixation. The device is made from medical grade titanium, stainless steel and UHMWPE suture and is provided sterile.

    AI/ML Overview

    The provided text is a 510(k) premarket notification summary for a medical device called "Parcus Synd-EZ SS." This document is a regulatory filing that demonstrates substantial equivalence to a predicate device, and as such, it does not contain acceptance criteria or detailed study information for new device performance.

    The primary purpose of this 510(k) is a labeling change for MR conditional parameters, indicating that the design, materials, and manufacturing processes of the device itself have not changed since its previous clearance (K192964). Therefore, the document explicitly states: "No new testing was completed, apart from the testing required to support MR Conditional parameters that was provided in this submission."

    Given this, I cannot extract the information you requested about acceptance criteria and proof of device performance for the medical functions of the Parcus Synd-EZ SS from this document. The document primarily focuses on the MR Conditional testing.

    However, I can provide the available information regarding the MR Conditional testing:

    Regarding MR Conditional Testing:

    1. Table of Acceptance Criteria and Reported Device Performance (for MR Conditional Parameters):

    Acceptance Criteria (MR Conditional)Reported Device Performance
    Magnetically induced forceDevice was tested for magnetically induced force and the results were used to establish MR system conditions suitable for safe use. (Specific values or thresholds not provided in the summary).
    Magnetically induced torqueDevice was tested for magnetically induced torque and the results were used to establish MR system conditions suitable for safe use. (Specific values or thresholds not provided in the summary).
    Heating by RF fieldsDevice was tested for heating by RF fields and the results were used to establish MR system conditions suitable for safe use. (Specific values or thresholds not provided in the summary). Note: The document indicates "The Synd-EZ SS was evaluated for use in the MR Environment and were determined to fit the definition of MR Conditional." This implies it met the relevant safety thresholds.
    Image artifactDevice was tested for image artifact and the results were used to establish MR system conditions suitable for safe use. (Specific values or thresholds not provided in the summary).

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

    • Sample Size: "worst-case device was selected for testing." The exact number of devices tested is not specified, but it implies a single representative device or a small number to characterize the "worst-case."
    • Data Provenance: Not explicitly stated, but assumed to be from internal testing conducted by Parcus Medical, LLC (or a contracted lab) to comply with FDA guidance and ASTM standards. This would be prospective testing specifically for this submission.

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

    • Not applicable for MR Conditional testing. MR Conditional testing relies on standardized physical measurements and engineering evaluations against defined limits, not expert clinical consensus on a "ground truth" derived from patient data.

    4. Adjudication method for the test set:

    • Not applicable. MR Conditional testing involves objective measurements rather than adjudication of interpretations.

    5. If a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was done:

    • No, an MRMC study was not done. This type of study is for evaluating human performance with and without AI assistance, which is not relevant to MR Conditional testing of a physical implant.

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

    • Not applicable. This is not an AI/algorithm-based device.

    7. The type of ground truth used:

    • For MR Conditional testing, the "ground truth" is defined by the safety limits and thresholds established in regulatory guidance (FDA Guidance Document - Establishing Safety and Compatibility of Passive Implants in the Magnetic Resonance (MR) Environment) and applicable ASTM standards.

    8. The sample size for the training set:

    • Not applicable. This is not an AI/machine learning device that requires a training set.

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

    • Not applicable.

    In summary, this document is a regulatory submission focused on demonstrating substantial equivalence and providing MR Conditional labeling. It does not provide detailed performance data or clinical study results for the device's primary indications, as those would have been covered in the original 510(k) clearances (K191783 and K192964) to which this device is substantially equivalent.

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    K Number
    K192964
    Date Cleared
    2019-11-22

    (30 days)

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

    Parcus Synd-EZ SS

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

    The Parcus Synd-EZ SS is intended to be used as an adjunct in fracture repair involving metaphyseal and periarticular small bone fragments where screws are not indicated, and as adjuncts in external and intramedullary fixation systems involving plates and rods, with fracture braces and casting.

    The Parcus Synd-EZ SS is intended to provide fixation during the healing process following syndesmotic trauma, such as fixation of the syndesmosis (syndesmosis disruptions) in connection with Weber B and Weber C ankle fractures.

    Device Description

    The Parcus Synd-EZ SS consists of two buttons with suture connecting them and are designed to be used for stabilizing the syndesmosis during healing. Building upon the technology of the Parcus Synd-EZ Ti, the Synd-EZ SS is easily adjusted for length and resists elongation without requiring knots to secure the fixation. The device is made from medical grade titanium, stainless steel and UHMWPE suture and is provided sterile.

    AI/ML Overview

    The provided text describes the Parcus Synd-EZ SS, a medical device intended for fracture repair and syndesmotic fixation. However, the document does not contain the detailed information necessary to fully answer your request regarding acceptance criteria and a study proving the device meets them, especially in the context of AI/algorithm performance.

    Here's what can be extracted and what is missing:


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

    The document provides a general statement about performance testing but does not offer a table of specific acceptance criteria or quantitative performance metrics.

    Acceptance CriteriaReported Device Performance
    Not explicit. The document states "Devices were evaluated for strength and elongation under cycle loading and ultimate failure conditions." The specific numerical thresholds for these evaluations are not provided."Results were compared with test data for the predicate device and demonstrated substantial equivalency." This indicates the device performed comparably to a predicate device, but specific performance numbers are absent.

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    This information is not available in the provided text. The document mentions "Devices were assembled to test blocks," implying laboratory testing, but does not specify the sample size or any data provenance related to human subjects or clinical data.

    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)

    This information is not available in the provided text. The device described is a physical implant, not an AI or diagnostic tool that would typically involve expert-established ground truth for performance evaluation in the way you've framed the question. The "testing" referred to is mechanical.

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

    This information is not available in the provided text. Adjudication methods are typically used in clinical trials or studies involving expert interpretation, which is not described here for this mechanical 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

    This information is not available in the provided text. The device is a surgical implant and does not involve AI assistance for human readers. Therefore, an MRMC study related to AI effectiveness is not relevant to this device.

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

    This information is not available in the provided text. The device is a physical implant and does not involve an algorithm.

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

    The "ground truth" for this device's performance would be established through mechanical test standards and material properties. The document states that "Devices were evaluated for strength and elongation under cycle loading and ultimate failure conditions." This implies engineering and biomechanical testing, where the "ground truth" is defined by established engineering principles and benchmarks for such implants. It's not clinical "ground truth" in the sense of diagnosis or pathology.

    8. The sample size for the training set

    This information is not available in the provided text. The document describes a physical medical device, not an AI/machine learning model that would have a "training set."

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

    This information is not available in the provided text. This question is not applicable as there is no mention of a training set or AI model.


    Summary of what the document does indicate about performance:

    • Type of Study: Laboratory performance testing ("side by side with the predicate device").
    • Parameters Evaluated: Strength and elongation under cyclic loading and ultimate failure conditions.
    • Conclusion: The device "demonstrated substantial equivalency" to the predicate device (Parcus Synd-EZ Ti, K191783).
    • Other Testing: LAL (Limulus Amebocyte Lysate) testing for pyrogenicity and a biocompatibility assessment in alignment with ISO 10993-1 were also conducted.

    This document focuses on the regulatory clearance for a physical medical device based on substantial equivalence to a predicate device, primarily through mechanical testing and biocompatibility assessments. It does not pertain to the evaluation of AI systems or diagnostic performance as implied by many of your questions.

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