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510(k) Data Aggregation

    K Number
    K193308
    Date Cleared
    2020-02-23

    (86 days)

    Product Code
    Regulation Number
    888.3020
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    T2 Alpha Tibia Nailing System, IMN Screws System

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

    The indications for use of this internal fixation device include:

    • Open and closed tibial fractures
    • Pseudoarthrosis and correction osteotomy
    • Pathologic fractures, impending pathologic fractures, and tumor resections
    • Fractures involving osteopenic and osteoporotic bone
    • Nonunion and malunion
      The End Cap Lower Extremity and the Nail Holding Screw Tibia / Femur PF may also be used in conjunction with the T2 Alpha Femur Antegrade GT/PF Nailing System.

    The IMN Screws System is intended to stabilize the intramedullary nail-bone construct for temporary stabilization.

    Device Description

    The T2 Alpha Tibia Nailing System is a fracture fixation system and includes sterile implants (tibial nails in various diameters, compression screw tibia and end caps) as well as non-sterile instruments (targeting devices). The sterile implants are made of titanium alloy (Ti6A14V ELI) per ASTM F136. The adapters and nail holding screws are manufactured from stainless steel. The Targeting Arm Tibia and Adjusting Device Tibia are made of stainless steel. PEEK unreinforced as well as PEEK with 30% and 50% carbon fibers. The Distal Targeting Arm Tibia is made of PEEK with 30% and 50% carbon fibers.

    The IMN Screws System includes bone screws (locking screws and advanced locking screws) that are inserted through the intramedullary nail to stabilize the nail-bone construct. All screws are made of titanium allov (Ti6Al4V ELI) per ASTM F136.

    AI/ML Overview

    The provided FDA 510(k) summary (K193308) for the Stryker T2 Alpha Tibia Nailing System and IMN Screws System does not contain information related to software-based medical devices, AI/ML performance, or human-reader studies. Therefore, I cannot extract the acceptance criteria and study details as requested for such systems.

    The document discusses implantable medical devices (intramedullary rods and bone screws) and focuses on demonstrating substantial equivalence to predicate devices through mechanical testing and material compatibility analyses.

    Here’s a breakdown of what is available in the document, which falls under traditional medical device clearance, not AI/software:

    1. Table of Acceptance Criteria and Reported Device Performance

    This table would typically be relevant for software performance metrics (e.g., sensitivity, specificity, AUC). For this device, the "acceptance criteria" are implied by the mechanical testing standards and successful demonstration of substantial equivalence.

    Performance Metric (Implicit Acceptance Criteria)Reported Device Performance
    T2 Alpha Tibia Nailing System
    Mechanical Properties per ASTM F1264Demonstrated substantial equivalence to predicate devices (K191271, K003018).
    Fatigue Strength Testing (distal)Demonstrated substantial equivalence to predicate devices (K191271, K003018).
    MR Conditional (Displacement force, torque, RF-induced heating, image artifacts)Demonstrated to be MR conditional.
    Bacterial Endotoxin TestingSterile implants meet specified endotoxin limit.
    IMN Screws System
    Mechanical Properties per ASTM F543 and F1264Demonstrated substantial equivalence to predicate devices (K191271) and reference devices (K003018, K040762).
    MR Conditional (Displacement force, torque, RF-induced heating, image artifacts)Demonstrated to be MR conditional.
    Bacterial Endotoxin TestingAdvanced locking screws meet specified endotoxin limit.

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

    This information is not applicable. The "test set" here refers to physical samples for mechanical and biological testing, not a dataset for an AI model.

    • Sample Size: Not specified in terms of number of devices tested, but mechanical tests were performed.
    • Data Provenance: Not applicable in the context of clinical data for AI. These are laboratory-based mechanical and material test results.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    Not applicable. "Ground truth" in this context would be the physical properties confirmed by mechanical tests and material analyses, not human interpretation of medical images or data.

    4. Adjudication Method

    Not applicable. There is no adjudication process described for the mechanical test results.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No. The document explicitly states: "No clinical testing of the T2 Alpha Tibia Nailing System has been conducted." and "No clinical testing of the IMN Screws System has been conducted."

    6. Standalone (Algorithm Only) Performance

    Not applicable. This device is not an algorithm or software.

    7. Type of Ground Truth Used

    For mechanical testing, the "ground truth" is defined by the physical behaviors and material properties measured according to established ASTM standards (e.g., ASTM F1264 for intramedullary fixation rods, ASTM F543 for metallic bone fixation fasteners). For MR compatibility, it relates to the measured displacement, torque, heating, and artifact characteristics in an MR environment. For bacterial endotoxin, it refers to a specified endotoxin limit.

    8. Sample Size for the Training Set

    Not applicable. This device does not use a "training set" in the context of AI/ML.

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

    Not applicable.

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    Why did this record match?
    Device Name :

    T2 Alpha Femur Antegrade GT/PF Nailing System, T2 Alpha Tibia Nailing System, IMN Screws System, IMN

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

    The indications for use of these internal fixation devices include:

    • Fixation of subtrochanteric, intertrochanteric, ipsilateral neck/shaft, comminuted proximal femoral shaft fractures
    • Femoral fixation required as a result of pathological disease
    • Temporary stabilization of fractures of the femoral shaft ranging from the femoral neck to the supracondylar regions of the femur
    • Open and closed femoral fractures
    • Pseudoarthrosis and correction osteotomy
    • Pathologic fractures, impending pathologic fractures and tumor resections
    • Ipsilateral femur fractures
    • Fractures proximal to a total knee arthroplasty
    • Nonunions and malunions
    • Fractures involving osteopenic and osteoporotic bone

    The indications for use of this internal fixation device include:

    • Open and closed tibial fractures
    • Pseudoarthrosis and correction osteotomy
    • Pathologic fractures, impending pathologic fractures, and tumor resections
    • Fractures involving osteopenic and osteoporotic bone
    • Nonunion and malunion
      The End Cap Lower Extremity and the Nail Holding Screw Tibia / Femur PF may also be used in conjunction with the T2 Alpha Femur Antegrade GT/PF Nailing System.

    The IMN Screws System is intended to stabilize the intramedullary nail-bone construct for temporary stabilization.

    The IMN Instruments System is intended to enable the implantation of intramedullary nail and screw.

    Device Description

    A Special 510(k) submission is being supplied to the U.S. FDA to gain clearance for modifications to the existing T2 Alpha Femur Antegrade GT/PF Nailing System, T2 Alpha Tibia Nailing System, IMN Screws System and IMN Instruments System previously cleared in K180436. Modifications include an increase of shelf-life from 5 years to 10 years for the sterile implants and a change of dimensional specifications for the Advanced Locking Screw, Targeting Arm Femur GT and Targeting Arm Femur PF.

    The T2 Alpha Femur Antegrade GT/PF Nailing System previously cleared in K180436 is a fracture fixation system and includes sterile implants (femoral nails in various diameter and sizes, compression screw femur, set screws and end caps) as well as non-sterile instruments (targeting devices).

    The T2 Alpha Tibia Nailing System previously cleared in K180436 is a fracture fixation system and includes sterile implants (tibial nails in various diameter, compression screw tibia and end caps) as well as non-sterile instruments (targeting devices).

    The IMN Screws System previously cleared in K180436 includes bone screws (locking screws and advanced locking screws) that are inserted through the intramedullary nail to stabilize the nail-bone construct.

    The IMN Instruments System includes the distal targeting device femur antegrade previously cleared in K180436. There are also associated surgical instruments (class I devices) that support the implantation and extraction of intramedullary nails and screws.

    AI/ML Overview

    This document describes a Special 510(k) Premarket Notification for modifications to existing intramedullary nailing systems (T2 Alpha Femur Antegrade GT/PF Nailing System, T2 Alpha Tibia Nailing System, IMN Screws System, and IMN Instruments System). The submission's purpose is to demonstrate substantial equivalence to the previously cleared predicate device (K180436) for these modifications.

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance Criteria (for modifications)Reported Device Performance (supporting modifications)
    Maintain packaging integrity and functionality for increased shelf-life.Packaging testing performed using methods consistent with the predicate device.
    No new worst-case scenarios identified through risk analysis.Risk analysis (per DIN EN ISO 14971) demonstrated no new worst case.
    Verification and validation methods for modifications are the same as for the original predicate device.Same verification and validation methods applied as for the predicate (K180436).
    Device remains as safe and effective as the predicate device.Risk analysis demonstrated the subject device is as safe and effective as the predicate device.
    Dimensional specifications meet established criteria.Specification review and dimensional analysis performed using the same protocol as the original submission.
    Acceptance criteria for dimensional changes are not altered from original device.Acceptance criteria were not altered from those used for the original device.
    No additional types of evaluation needed for dimensional changes.No additional types of evaluation are needed for dimensional changes.

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

    The document explicitly states: "No clinical testing of the T2 Alpha Femur Antegrade GT/PF Nailing System has been conducted." This indicates that there was no "test set" in the context of clinical performance evaluation. The data provenance supporting the modifications (shelf-life increase and dimensional changes) would be from in-house engineering and quality testing, likely conducted by Stryker Trauma GmbH in Schoenkirchen, Germany. These are likely retrospective data based on existing product infrastructure.

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

    As no clinical testing was conducted and the performance data primarily relates to engineering and quality assessments for modifications, there is no mention of "experts" establishing ground truth in the context of a clinical test set. The validation would have been performed by qualified engineers and quality control personnel within Stryker Trauma GmbH.

    4. Adjudication Method for the Test Set:

    Not applicable, as no clinical test set requiring adjudication by experts was used for this Special 510(k) submission.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

    No MRMC comparative effectiveness study was mentioned or performed. The submission is for modifications to an existing device, and clinical efficacy was not under evaluation, nor was comparison with human readers.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:

    Not applicable, as this device is a physical medical implant system, not a software algorithm or AI-powered device.

    7. Type of Ground Truth Used:

    The "ground truth" for this submission's modifications primarily relies on:

    • Engineering specifications and data: For dimensional changes, ensuring the modified components still meet their intended design parameters.
    • Packaging integrity and sterility data: For the shelf-life extension, ensuring the packaging maintains sterility and functionality over the new extended period.
    • Risk analysis methodology: As per DIN EN ISO 14971, to confirm that the changes do not introduce new hazards or increase existing risks.

    These are established through internal quality and engineering testing, not clinical outcomes, pathology, or expert consensus on patient data.

    8. Sample Size for the Training Set:

    Not applicable, as this is a physical medical device and not an AI/ML algorithm requiring a training set.

    9. How the Ground Truth for the Training Set Was Established:

    Not applicable, for the reasons stated above.

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