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510(k) Data Aggregation

    K Number
    K203468
    Date Cleared
    2021-12-20

    (390 days)

    Product Code
    Regulation Number
    880.6850
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The THINK Surgical TCAT® TKA Instrument Tray is intended to protect, organize and deliver to the surgical field TCAT® tools, instruments and accessories. The tray allows sterilization of TCAT® tools, instruments and maintains sterility of the enclosed devices until used. The tray is wrapped with an FDA-cleared sterilization wrap during the pre-vacuum autoclave sterilization process.

    Device Description

    The TCAT® TKA Instrument Tray is intended only for use with TSolution One® Total Knee Application instruments, tools and accessories. This tray is used to enclose and hold the instruments, tools and accessories in an organized manner during the sterilization process and subsequent storage and transportation to and from the surgical suite. The tray is designed to fit any standard autoclave and is constructed primarily of anodized aluminum. The tray is compatible with repeated steam sterilizations. The tray has perforations to facilitate sterilant penetration, evacuation and drying. Since the tray is perforated, an FDA-cleared sterilization wrap must be used to maintain sterility of the contents. The trav has the basic same size and a minor configuration change to the predicate device: a rectanqular base with a latchable lid and a lift out tray. The tray has perforations with an evenly distributed hole pattern on the lid, bottom, and sides to allow sterilant penetration. The bottom tray surface and lift out tray surface contain stanchions designed to separately hold each individual instrument, tool and accessory for effective sterilant exposure, sterilant evacuation and drying the entire duration of the sterilization process, as well as ease of locating each instrument when placing in or removal from the tray. The lift out tray contains a silicone mat which may used to sterilize additional THINK Surgical part.

    AI/ML Overview

    This document describes the TCAT® TKA Instrument Tray, a Class II medical device intended to protect, organize, and facilitate the sterilization of surgical tools and instruments for total knee arthroplasty (TKA) procedures.

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for the TCAT® TKA Instrument Tray are based on non-clinical performance testing. The "Results" column in the table below effectively serves as the reported device performance.

    Non-Clinical Performance TestingAcceptance Criteria & PurposeReported Device Performance
    Sterilization EfficacyPurpose: To verify the sterilization efficacy. The instrument tray, with maximum load and inoculated biological indicators (BIs) in difficult-to-penetrate areas, was wrapped in an FDA-cleared sterilization wrap. Acceptance Criteria: The results should indicate a six-log reduction of the indicator organism (BI Overkill method). Standard Followed: ANSI/AAMI/ISO 14937:2013 – Sterilization of Healthcare Product – General Requirements for Characterization of a Sterilizing Agent and the Development, Validation and Routine Control of a Sterilization Process for Medical Devices.PASS
    Shipping/PackagingPurpose: To evaluate the TCAT® TKA Instrument Tray with maximum load in its shipping configuration. Acceptance Criteria: Packaging requirements must be met. Standard Followed: ASTM D4169-16, Standard Practice for Performance Testing of Shipping Containers and Systems.PASS
    Handle Strength TestingPurpose: To evaluate the handle strength of the TCAT® TKA Instrument Tray. Acceptance Criteria: The handle strength should meet the requirements specified by the standard. Standard Followed: ASTM ST77:2013, Containment Devices for Reusable Medical Device Sterilization.PASS
    Verification of Instrument Tray Product Requirements by Inspection and AnalysisPurpose: To visually inspect the instrument tray per specifications and inspect and analyze documents to identify design outputs. These design outputs are then verified against corresponding product requirements. Acceptance Criteria: Design outputs must be verified against corresponding product requirements. Standard Followed: THINK Surgical developed specification.PASS
    Verification of Instrument Tray Product Requirements by Lab TestPurpose: To perform physical, non-destructive testing of the instrument tray to verify design outputs against corresponding product requirements. Acceptance Criteria: Design outputs must be verified against corresponding product requirements through physical testing. Standard Followed: THINK Surgical developed specification.PASS

    Study Proving Device Meets Acceptance Criteria:

    The device's compliance with the acceptance criteria is demonstrated through a series of non-clinical performance testing summarized in Table 5 of the provided document.

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

    • Sample Size: The document does not explicitly state the numerical sample size for each test. For tests like Sterilization Efficacy, it mentions "the TCAT® TKA Instrument Tray contained the maximum load," implying at least one tray was tested under specified conditions. For Shipping/Packaging, it states "The TCAT® TKA Instrument Tray was evaluated," suggesting at least one or a small number of trays were subjected to the tests.
    • Data Provenance: The data is based on non-clinical testing performed in a laboratory setting by THINK Surgical, Inc., or a qualified testing facility. The document does not specify a country of origin for the data beyond the manufacturer's location in Fremont, CA, USA. The data is prospective as it was generated specifically for the 510(k) submission to demonstrate the device's performance.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
    This information is not applicable to this type of device and testing. The tests conducted are non-clinical (e.g., sterilization efficacy, mechanical strength) and rely on established scientific protocols, standards (e.g., ANSI/AAMI/ISO, ASTM), and laboratory measurements, not expert human interpretation of medical data. Therefore, there is no "ground truth" derived from medical experts for these specific tests.

    4. Adjudication Method for the Test Set
    This is not applicable. As mentioned above, the tests are objective, standardized non-clinical evaluations rather than subjective interpretations requiring adjudication among experts. The results are typically "Pass" or "Fail" against predefined criteria within the respective standards.

    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. The device is an instrument tray for surgical tools and sterilization. It is not an AI-powered diagnostic or assistive tool that would involve human readers or image interpretation. Therefore, an MRMC study comparing human readers with and without AI assistance is not relevant to this device.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
    This is not applicable. The device is a physical instrument tray, not an algorithm or AI system.

    7. The type of ground truth used
    As explained in point 3, the concept of "ground truth" established by human experts or pathology is not applicable here. Instead, the "ground truth" for the non-clinical tests is based on:

    • Standardized protocols and scientific principles: For sterilization, the "ground truth" is a 6-log reduction of biological indicators, a universally accepted benchmark for sterility assurance.
    • Engineering specifications and test methods: For mechanical properties (e.g., handle strength, shipping integrity), the "ground truth" is adherence to established industry standards (ASTM) and internal THINK Surgical specifications.
    • Measurable physical parameters: For dimensional verification and material composition, the "ground truth" is direct measurement and material analysis.

    8. The Sample Size for the Training Set
    This is not applicable. The device is a physical instrument tray, not software or an AI model that requires a training set.

    9. How the Ground Truth for the Training Set Was Established
    This is not applicable for the same reason as point 8.

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    K Number
    K200632
    Date Cleared
    2020-04-08

    (29 days)

    Product Code
    Regulation Number
    880.6850
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The THINK Surgical TCAT® TKA Instrument Tray Set is intended to protect, organize, and deliver to the surgical field TCAT® tools, instruments and accessories. The trays allow sterilization of tools, instruments and accessories, and maintain sterility of the enclosed devices until used. The trays are wrapped with an FDA-cleared sterilization wrap during the pre-vacuum autoclave sterilization process.

    Device Description

    The TCAT® TKA Instrument Tray Set is intended only for use with TSolution One® Total Knee Application instruments, tools and accessories. These trays are used to enclose and hold the instruments tools and accessories in an organized manner during the sterilization process and subsequent storage and transportation to and from the surgical suite. The trays are designed to fit any standard autoclave and are constructed primarily of anodized aluminum meeting biocompatibility requirements and are compatible with repeated steam sterilizations. The trays have perforations to facilitate sterilant penetration, evacuation and drying. Since the trays are perforated, an FDA-cleared sterilization wrap must be used to maintain sterility of the contents.

    The trays have the same size and same basic configuration of the predicate device: a rectangular base with a latchable lid. The trays have perforations with an evenly distributed hole pattern on the lid, bottom, and sides to allow sterilant penetration. The bottom surface and interior shelves of the trays contain stanchions designed to separately hold each individual instrument, tool and accessory for effective sterilant exposure, evacuation and drying during the entire duration of the sterilization process, as well as ease of locating each instrument when placing in or removal from the tray.

    The sterilization trays have been tested only with THINK Surgical instruments, tools and accessories for a 4 minute sterilization cycle of pre-vacuum steam sterilization at 132°C, with a 45 minute dry time. While reuseable, these trays will not be serviced or repaired.

    AI/ML Overview

    The provided document, K200632, details the 510(k) premarket notification for the THINK Surgical TCAT® TKA Instrument Tray Set. It focuses on demonstrating substantial equivalence to a predicate device (TCAT® THA Instrument Tray Set) through non-clinical performance testing.

    Here's an analysis of the acceptance criteria and the study proving the device meets them, based on the provided text:

    Device: TCAT® TKA Instrument Tray Set
    Purpose of Device: Intended to protect, organize, and deliver TCAT® tools, instruments, and accessories to the surgical field, allow for their sterilization, and maintain sterility.


    1. Table of Acceptance Criteria and Reported Device Performance

    Non-Clinical Performance TestingPurpose (What was being tested)Acceptance CriteriaReported Device Performance/Results
    Sterilization EfficacyTo verify the TCAT® TKA Instrument Tray Sets containing the maximum load were inoculated with biological indicators placed in areas of the trays deemed most difficult for sterilant (steam) to penetrate. Following inoculation, the trays were wrapped in FDA-cleared sterilization wraps.- All biological indicators (BIs) must be incubated for a minimum of 7 days at 55°C-60°C- The positive control for the SAL testing must show characteristic growth of the indicator organism- Valid temperature data must be collected for each product probe location- Temperature probes used during profiling of the test article must be within ±0.5°C of at least one post calibration reference temperature that is representative of the profiling cycles- All directly-inoculated test article components must demonstrate to contain no bacteriostatic properties by showing growth of G. stearothermophilus during method suitability testingThe study indicated that the BI Overkill method provided a six-log reduction of the indicator organism.
    PackagingTo verify the TCAT® TKA Instrument Tray Sets were evaluated with maximum load, wrapped according to use instructions and in the shipping configuration according to a shipping validation test.- Is the packaging or parts of the Application Tray damaged?- Is the Packaging or parts of the Base Tray damaged?- Are the labels and packing list still affixed and legible?PASS
    ReprocessingTo verify the TCAT® TKA Instrument Tray Sets were evaluated for cleanability according to the user instructions.- Observer shall provide each participant with an IFU- Observer shall ask each participant to read the IFU carefully- Observer shall ask each user to simulate the reprocessing steps according to the IFU- Observer shall fill out the data collection sheetThe table states "indicates all reprocessing steps PASS" as part of the criteria, implying that the passing of these observational checks constitutes the acceptance.PASS
    BiocompatibilityTo verify the TCAT® TKA Instrument Tray Sets were evaluated for biocompatibility according to ISO 10993-1.MEM Elution Study: Test article meets a passing score of 2 or below; test article is not considered to have a cytotoxic potential.PASS
    Use and Sterile Processing GuideTo verify the TCAT® TKA Instrument Tray Sets were evaluated in accordance with the appropriate guidances. (This likely refers to ease of use and ability to properly load/unload for sterile processing).- Participant is able to load components in the tray- Participant is able to load components in the tray with the aid of visual indications showing storage location of each instrument- Participant is able to carry one Instrument Tray- Participant is able to load all components in the tray without requiring an additional toolParticipant is able to remove all components in the tray without requiring an additional toolPASS

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

    The document does not explicitly state the specific sample sizes (number of trays or iterations) used for each test. For tests like "Sterilization Efficacy," it refers to "TCAT® TKA Instrument Tray Sets containing the maximum load," implying multiple units were tested to ensure robustness. Similarly, for "Packaging" and "Reprocessing," the evaluation would involve a certain number of units.

    Data Provenance: The document does not specify the country of origin for the data. The studies are non-clinical (laboratory-based) and conducted to regulatory standards (e.g., ANSI/AAMI/ISO, ASTM, ISO 10993), which typically do not involve human subjects or retrospective/prospective data collection from clinical practice. They are "prospective" in the sense that the tests were designed and executed to evaluate the device.


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

    The document does not mention the use of external experts or their qualifications for establishing ground truth for any of the non-clinical tests. For the reprocessing and use guidance tests, an "Observer" is mentioned, who would likely be trained personnel conducting the evaluation according to a defined protocol. These are laboratory-based engineering and performance validation tests, not clinical studies requiring physician or radiologist expertise for ground truth.


    4. Adjudication Method for the Test Set

    Adjudication methods (like 2+1, 3+1) are typically used in clinical studies for interpretation of imaging or clinical outcomes by multiple experts. Since this submission relates to a non-clinical device performance evaluation (sterilization, packaging, cleaning, biocompatibility, ease of use of a surgical tray), such adjudication methods are not applicable and are not mentioned in the document. The tests have predefined, measurable acceptance criteria.


    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

    No, an MRMC comparative effectiveness study was not done. MRMC studies are relevant for AI/imaging devices where human interpretation of medical images is involved, to assess the impact of AI assistance on human reader performance. This device is a surgical instrument tray (sterilization wrap, not an imaging or diagnostic AI), and as such, MRMC studies are not applicable. The document explicitly states: "No clinical or animal testing were required."


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

    This question is not applicable to the device described. This is a physical medical device (an instrument tray for sterilization), not an algorithm or AI system. Therefore, the concept of "standalone performance" for an algorithm doesn't apply. The tests described are for the physical properties and performance of the tray itself.


    7. The Type of Ground Truth Used

    The "ground truth" for these non-clinical tests is established by:

    • Physical/Biological Standards: For sterilization efficacy, the ground truth is the complete eradication of specified biological indicators (e.g., 6-log reduction of G. stearothermophilus spores), verified through incubation protocols.
    • Engineered Specifications and Standards: For packaging, cleaning, biocompatibility, and use, the ground truth is defined by meeting pre-specified engineering tolerances, regulatory standards (e.g., ISO, ASTM), and user requirements (e.g., no damage, legible labels, cytotoxic potential score, ability to load instruments without additional tools). These are objective, measurable criteria.

    8. The Sample Size for the Training Set

    Not applicable. This product is a physical device (surgical instrument tray), not an AI/machine learning model that requires a training set.


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

    Not applicable for the reason stated above.

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