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510(k) Data Aggregation
(22 days)
Freedom® Total Knee System Titanium Tibial Base Plate
The Freedom® Total Knee System is indicated for the following:
- Severe knee joint pain, loss of mobility, and disability due to: rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis.
- Correction of functional deformities.
- Post-traumatic loss of knee joint contour, particularly when there is patellofemoral erosion, dysfunction, or prior patellectomy.
- Moderate valgus, varus, or flexion trauma.
- Knee fractures untreatable by other methods.
- Revision surgery where sufficient bone stock and soft tissue integrity are present (For PCK Components and Primary PCK Components only).
The Freedom® Total Knee System – Titanium Tibial Base Plate is intended for cemented and single use only.
The Freedom® Total Knee System is comprised of a femoral component, all-poly tibial component, patellar component, tibial base plate and tibial articular surface. The Freedom® Total Knee System's Femoral Component is offered as different versions such as stemmed PCK design, primary PCK, cruciate retaining, posterior stabilizing. The Freedom® Total Knee System's Tibial Base Plate is offered with stemmed design and without stemmed design. The Freedom® Total Knee System was originally cleared under the 510(k) number K082019. Later on, several modifications were made and were cleared under 510(k)s K091280, K192148, K090411, K182574, K131481, K111785 and K200912 respectively.
The primary purpose of this special 510(k) Device Modification to the Freedom® Metal Backed Tibial Component (K090411) is to notify the FDA of the change in materials used to manufacture the tibial base plate from CoCrMo to Wrought Titanium-6Aluminium-4Vanadium ELI Alloy (Ti6Al4V ELI, ASTM F136-13) as an alternative material option for the tibial base plate.
The Titanium Tibial Base Plate is fabricated from Titanium alloy Ti-6Al-4V ELI, compliant with ASTM F136 and is intended for cemented application to replace the articulating surface of the proximal tibia in a measured resection technique.
The Titanium Tibial Base Plates are available in 8 different sizes (1 to 8) based on Anterior/Posterior (A/P) and Medial/Lateral (M/L) dimensions.
This 510(k) clearance letter pertains to a Class II medical device, specifically the Freedom® Total Knee System - Titanium Tibial Base Plate (K251717). The submission is a special 510(k) Device Modification, indicating that the changes made to the device are well-defined and do not significantly alter the indications for use or raise new questions of safety and effectiveness.
The core change is the material of construction for the tibial base plate, shifting from CoCrMo to Wrought Titanium-6Aluminium-4Vanadium ELI Alloy (Ti-6Al-4V ELI). The design, geometry, surfaces, and locking features remain identical to the previously cleared predicate device (K090411).
Therefore, the acceptance criteria and the study proving the device meets these criteria primarily focus on mechanical performance and biocompatibility related to this material change, rather than extensive clinical efficacy studies or comparative effectiveness studies involving human readers, as would be typical for AI/software devices.
Acceptance Criteria and Reported Device Performance
Given the nature of this submission (a material change for an orthopedic implant with identical design), the acceptance criteria are not explicitly numerical thresholds like sensitivity/specificity, but rather involve demonstrating mechanical equivalence to the predicate device and biocompatibility of the new material.
Here's a table summarizing the implicit acceptance criteria based on standard regulatory requirements for such a device modification, and how the document indicates they were met:
Acceptance Criteria Category | Specific Criteria (Implicit from Submission Type) | Reported Device Performance (as per 510(k) Summary) |
---|---|---|
Mechanical Performance | The Titanium Tibial Base Plate must demonstrate equivalent or superior mechanical integrity and fatigue resistance compared to the predicate device to ensure durability and prevent failure under intended physiological loads. | Met. "The design, geometry, surface features, locking features and dimensional attributes of the Titanium Tibial Base Plate are identical to those of the previously cleared Freedom® Metal Backed Tibial Base Plate (K090411)." |
"Hence, to evaluate the device function and performance for its intended use, the Freedom® Titanium Tibial Base Plate was subjected to the following mechanical tests:Tibial Tray Fatigue Testing per ASTM F1800Range of Motion & Modular disassembly testing was leveraged from the reference device (K090411) as the subject device uses an identical tibial insert locking mechanism." | ||
Material Biocompatibility | The new material (Ti-6Al-4V ELI) must be biocompatible and not elicit adverse biological responses (e.g., toxicity, sensitization, irritation) when implanted in the human body. | Met. "Biocompatibility testing is not required for the subject Titanium Tibial Base Plate device, because the material, Ti-6Al-4V ELI Titanium Alloy is compliant with ASTM F136, is a well-established material with a long history of safe use in orthopedic implants." |
"This material has been used extensively for many years without any major biocompatibility related safety concerns." | ||
"Additionally, the material has been used in multiple components of Maxx Orthopedics' previously cleared Freedom® Total Knee System…" | ||
"It also complies with the biocompatibility requirements outlined in 'Class II Special Controls Guidance Document: Knee Joint Patellofemorotibial and Femorotibial Metal/Polymer Porous-Coated Uncemented Prostheses; Guidance for Industry and FDA'". | ||
"Furthermore, Ti-6Al-4V ELI Titanium Alloy (ASTM F136) has also been used in similar tibial base plate components from other legally marketed devices, intended for same anatomical location and patient contact type, as demonstrated in K220737." | ||
"A risk-based assessment, following the principles outlined in FDA's 2023 Biocompatibility guidance (Use of ISO 10993-1), confirms that the material change does not introduce new types of patient contact, contact duration, or clinical use conditions that would require additional biocompatibility testing." | ||
Equivalence in Design/Function | The device design must be substantially equivalent to the predicate, with any minor differences not raising new safety or effectiveness concerns. | Met. "The design, geometry, surface features, locking features and dimensional attributes of the Titanium Tibial Base Plate are identical to those of the previously cleared Freedom® Metal Backed Tibial Base Plate (K090411)." |
"There are no significant technological differences between the subject and predicate device. The subject device uses a similar design and dimensions, geometry and sizing, and achieves its intended use in an identical manner as the primary predicate and both devices are manufactured using similar subtractive manufacturing techniques." | ||
Sterilization Method (Minor Change) | If the sterilization method changes, its effectiveness must be validated. | Addressed. "Minor differences in subject device are that it uses different materials of constructions and sterilization method that are addressed via performance testing and similarity to the secondary predicate devices (K241597)." While not explicitly detailed, the mention implies this was covered. |
Study Details (Relevant to Orthopedic Implants, Not AI)
The provided text describes a submission for an orthopedic implant and does not involve an AI/software component, nor does it detail a clinical study with human patients for AI performance evaluation. Therefore, many of the requested points regarding sample sizes for test/training sets, expert readers, ground truth for AI, MRMC studies, etc., are not applicable to this type of device clearance and are consequently not found in the document.
However, based on the information provided, here's what can be inferred/stated:
-
Sample size used for the test set and data provenance:
- Test Set: Not applicable in the context of clinical AI performance data. For mechanical testing (ASTM F1800), standard test methods specify the number of samples required (e.g., minimum of 6 samples for fatigue per ASTM F1800-97), but the exact number used in this specific submission is not reported in the summary.
- Data Provenance: Not applicable for AI performance data. For material and design, the device is manufactured by Maxx Orthopedics Inc. (Norristown, PA, USA) and Meril Healthcare Pvt. Ltd. (Vapi, Gujarat, India).
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Number of experts used to establish the ground truth for the test set and qualifications of those experts:
- Not applicable as this is a mechanical and material modification, not an AI diagnostic device requiring expert interpretation of images for ground truth.
-
Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable for the type of device/study described.
-
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:
- No. This type of study (MRMC, AI assistance) is not relevant or performed for this device. The submission is for a physical orthopedic implant with a material change.
-
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable, as there is no algorithm or AI component in this device.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For the mechanical testing, the "ground truth" would be the engineering specifications and performance of the predicate device, alongside adherence to international standards (e.g., ASTM F1800).
- For biocompatibility, the "ground truth" is established long-term clinical use data, compliance with ASTM F136 (Standard Specification for Wrought Titanium-6Aluminum-4Vanadium ELI Alloy for Surgical Implant Applications), and prior FDA clearances of devices using this material.
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The sample size for the training set:
- Not applicable (no AI training set).
-
How the ground truth for the training set was established:
- Not applicable (no AI training set).
In summary, the FDA clearance for K251717 as a special 510(k) is based on demonstrating that the new Titanium Tibial Base Plate is mechanically equivalent to its predicate and that the new material is biocompatible and has a well-established history of safe use in similar orthopedic applications. The regulatory review focuses on engineering performance criteria and material biocompatibility rather than clinical performance data from patient studies or AI algorithm validation.
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(89 days)
Dentsply Sirona Titanium Bases system
The Dentsply Sirona Titanium Bases system is intended for use in partially or fully edentulous mandibles and maxillae in support of single cement-retained restorations.
For AT EV 3.0 S, AT TX 3.0 S, BH 3.0 S, and SB L 3.3 L titanium bases, the indication is restricted to the replacement of single lateral incisors in the maxilla and lateral and central incisors in the mandible.
The system comprises three parts:
- Abutment Block material (CEREC Cercon 4D Abutment Block)
- Titanium Base (TiBase)
- CAD/CAM system
The TiBase is recommended for use with two-piece hybrid abutments and hybrid abutment crowns, used in conjunction with endosseous dental implants.
The proposed Dentsply Sirona Titanium Bases system are connected to Dentsply Sirona or third-party dental implants to facilitate the prosthetic dental restoration of edentulous areas of the oral anatomy. The proposed TiBase components are assembled (through extraoral cement bonding) with the patient specific CEREC Cercon 4D Abutment Block (K234018), to form the complete, two-piece CAD/CAM Titanium Base system abutments. The bottom half of the abutment is the TiBase component, which interfaces with the implant system-specific geometry, while the top half of the abutment is the abutment block material that is milled to form either an abutment crown or a meso-structure (the latter is subsequently finished with a crown). The TiBase component therefore serves as the "platform" on which the customized milled abutment crown or the meso-structure is bonded to, forming the complete CAD/CAM Titanium Base system abutment. The completed CAD/CAM Titanium Base system abutment is attached to the dental implant with an abutment screw.
The TiBase system is part of a workflow that includes CAD/CAM software cleared in predicate device, K193408, CAD/CAM system with CEREC Chairside Software, and reference device, K200191, CAD/CAM System with inLab Software, and the abutment crown and meso-structure material cleared in reference device, K234018.
The TiBase components are made of the same material as the predicate device (K193408) TiBases, which is titanium alloy Ti6Al4V, complying with ASTM F136-13. While the lower part connects to the implant system, the upper part consists of a tapered, cylindrical center post which is designed to receive the abutment crown or meso-structure to complete the finished CAD/CAM abutment.
The TiBase components come in small and large sizes depending on the diameter size of the connecting implant. A notch feature on the cylindrical part of the upper portion (i.e. rotational reference and lock) ensures that there is only one position to mount either a scanbody or the abutment crown/meso-structure.
The TiBase component center post includes a through-channel through which a corresponding abutment screw is inserted to allow retention of the finished abutment to the implant. The abutment screw, made of the same Titanium material, when assembled with the proposed TiBase component, is located in the internal geometry of the titanium base and does not seat in the finalized abutment crown/meso-structure.
The minimum/maximum design specification limits are as follows:
- Maximum angulation for the Zirconia top-half material: 20˚
- Minimum wall thickness of the Zirconia top-half material: 0.5 mm
- Gingival heights of the TiBase component: 1, 2, 3 mm
- TiBase component post height (i.e., length above the gingival height): ≥ 4 mm
This document is a 510(k) clearance letter for the Dentsply Sirona Titanium Bases system, which specifies its indications for use and compares it to predicate and reference devices to demonstrate substantial equivalence. It does not describe the specific acceptance criteria and detailed study results that prove the device meets those criteria in a format applicable to AI/ML software performance studies.
The document details the technical aspects of the dental implant components and their mechanical testing for safety and performance (e.g., fatigue testing), biocompatibility, reprocessing validation, and MR compatibility. However, it does not involve the types of performance metrics, test set characteristics, or ground truth establishment typically associated with AI/ML device evaluations.
Therefore, for aspects related to AI/ML device performance (like accuracy metrics, expert review, MRMC studies, standalone performance), the answer is "Not applicable" or "Not provided" as this is a traditional medical device clearance, not an AI/ML software clearance.
Here's a breakdown of the requested information based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document describes several non-clinical tests that the device was subjected to and that it "met acceptance criteria" or "showed similar results" to reference devices. However, the specific quantitative acceptance criteria (e.g., "fatigue strength must be > X N") and the exact reported quantitative performance values achieved by the Dentsply Sirona Titanium Bases system are not explicitly stated in this clearance letter. The letter generally refers to compliance with standards.
For example, for fatigue testing, it states: "The TiBases systems were subjected to fatigue testing per the following requirements and showed similar results when compared to the reference devices (K213961, K241485)" and refers to ISO 14801:2016 and FDA Special Controls Guidance. It does not provide the numerical results or the specific acceptance mechanical load values. The same applies to MR testing, reprocessing, and biocompatibility.
Acceptance Criteria Category | Reported Device Performance |
---|---|
Fatigue Testing (per ISO 14801:2016 & FDA Special Controls Guidance) | |
Specific quantitative acceptance criteria (e.g., minimum load cycles at specified force) are not explicitly stated. | "met acceptance criteria" and "showed similar results when compared to the reference devices (K213961, K241485)". (Specific numerical results not provided). |
MR Testing (per ASTM F2052-21, F2213-17, F2119-07, CM&S for RF heating) | "met the following requirements and supports the MR Conditional labeling of the TiBases systems." (Specific numerical results not provided). |
Software System Verification (CAD/CAM compatibility) | "confirmed that the maximum and minimum design parameters for the customizable two-piece TiBase system abutment device are adequately locked into each of the compatible CAD/CAM software (K193408, K200191) and specifically into the available device design libraries integrated into the software." |
Reprocessing Testing (per ISO 17665-1:2006 & FDA Guidance) | "met acceptance criteria." (Specific numerical results not provided; included by reference to K234018). |
Biocompatibility Assessment (per ISO 10993-1:2018 & FDA Guidance) | "met acceptance criteria." (Specific numerical results not provided; testing performed via K234018). |
2. Sample size used for the test set and the data provenance
- Sample Size: Not explicitly stated in terms of the number of unique devices/tests in the provided text. The fatigue testing mentions "the proposed device performs as well as the reference devices (K213961, K241485)," implying a comparison and potentially new tests for the specific new TiBases. However, specific counts are not given.
- Data Provenance: The studies are non-clinical (laboratory tests) rather than human patient data. Therefore, "country of origin" and "retrospective/prospective" are not applicable in the context of patient data. The tests were performed to demonstrate compliance with international standards (ISO, ASTM) and FDA guidance.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not Applicable (N/A). This is a mechanical/material device clearance, not an AI/ML software evaluation based on expert-labeled data. The "ground truth" for these tests refers to the objective results conforming to engineering and material science standards (e.g., a device either fractures at a certain load or it doesn't, a material is biocompatible or not).
4. Adjudication method for the test set
- Not Applicable (N/A). Adjudication methods like 2+1 or 3+1 are used for resolving discrepancies in expert labeling for AI/ML ground truth, which is not relevant here.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done
- No. This is not an AI/ML software device that involves human interpretation of medical images.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Not Applicable (N/A). This is a physical device, not an algorithm. The "software system verification" refers to confirming that the CAD/CAM software correctly integrates the design parameters for the physical components, not an AI algorithm's standalone diagnostic performance.
7. The type of ground truth used
- For mechanical (fatigue) testing: Compliance with ISO 14801:2016 and FDA guidance, meaning the physical behavior of the device under specified loads.
- For MR testing: Compliance with ASTM standards, meaning objective measurements of displacement, torque, and image artifacts.
- For software verification: Conformation that design parameters are correctly implemented in CAD/CAM software.
- For reprocessing and biocompatibility: Compliance with ISO standards and FDA guidance, meaning objective evaluations of sterility and biological response.
8. The sample size for the training set
- Not Applicable (N/A). There is no AI/ML model involved; therefore, no training set.
9. How the ground truth for the training set was established
- Not Applicable (N/A). There is no AI/ML model involved; therefore, no training set.
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(325 days)
Eminent Spine 3D Titanium Pedicle Screw System
The Eminent Spine 3D Titanium Pedicle Screw System is designed to provide immobilization and stabilization to the thoracic, lumbar and sacral spinal segments as an adjunct to fusion. The system is intended for posterior, pedicle fixation in skeletally mature patients for the treatment of the following acute and chronic instabilities or deformities: severe spondylolisthesis (grades 3 or 4) of the L5-S1 vertebrae, degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, spinal stenosis, scoliosis, kyphosis, lordosis, spinal tumor, pseudoarthrosis and failed previous fusion.
The Eminent Spine 3D Titanium Pedicle Screw System consists of rods, polyaxial screws with set caps, and cross connectors with lock screws. Rods are 5.5mm in diameter and are available either straight or pre-contoured. Straight and pre-contoured rods are each offered in lengths ranging from 40mm to 600mm in various increments. The radius of curvature of the pre-contoured rods is 154mm throughout the entire series. Cannulated polyaxial screws are available in 6.0mm, 6.5mm, 7.0mm, 7.5mm, and 8.0mm diameters and in lengths ranging from 40mm to 60mm in 5mm increments. Set caps are used to fasten the rod and screw. Cross connectors are available in 3 length ranges: 32mm-42mm, 42mm-58mm, and 58mm-74mm. Cross connectors lock screws are used to fasten the cross connector together and fasten across the rods.
All components are manufactured from Ti6Al4V ELI. The screw is made specifically from Ti6Al4V ELI per ASTM F3001 and the tulip, set cap, rod, and cross link systems are made specifically from Ti6Al4V ELI per ASTM F136. The devices are sold non-sterile.
The provided document is an FDA 510(k) clearance letter for a medical device, the "Eminent Spine 3D Titanium Pedicle Screw System." This letter is a regulatory document, not a clinical study report.
Therefore, none of the information requested about acceptance criteria and study proving device performance (points 1-9) can be found in this document.
The document states that the device is "substantially equivalent" to legally marketed predicate devices, which is the basis for 510(k) clearance. This equivalence is primarily demonstrated through mechanical testing (listed on page 6) and comparison of technological characteristics (page 6), rather than clinical performance studies involving human subjects or AI algorithms.
Specifically, the document mentions:
- Mechanical Testing:
- Static torsion, static compression bending, and dynamic compression bending according to ASTM F1717
- Torsional strength, driving torque, and axial pullout according to ASTM F543
- Static cantilever bending according to ASTM F2193
- Dynamic cantilever bending modified from ASTM F2193
- Conclusion: "The results support the substantial equivalence of the subject device compared to predicate devices."
This type of submission typically relies on non-clinical data (e.g., bench testing) to demonstrate that the new device performs as safely and effectively as a legally marketed predicate device, and does not usually include the detailed clinical study data points requested (such as sample size for test/training sets, expert adjudication, MRMC studies, or AI algorithm performance).
In summary, the provided text does not contain the information necessary to address the specific questions about acceptance criteria and clinical study performance for human readers or AI, as it pertains to a mechanical medical device cleared through substantial equivalence based on bench testing.
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(48 days)
Adaptix Interbody System with Titan nanoLOCK Surface Technology
The Adaptix™ Interbody System with Titan nanoLOCK™ Surface Technology is intended to be used in spinal fusion procedures for patients diagnosed with Degenerative Disc Disease (DDD) at one or two contiguous levels from L2 to S1. DDD patients may also have up to Grade 1 Spondylolisthesis or retrolisthesis at the involved levels. DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. The Adaptix™ Interbody System with Titan nanoLOCK™ Surface Technology is intended for use with supplemental fixation systems cleared for use in the lumbar spine.
These patients should be skeletally mature and have had six months of nonoperative treatment. The Adaptix™ Interbody System with Titan nanoLOCK™ Surface Technology is intended to be used with autograft bone and/or allograft bone graft comprised of cancellous and/or corticocancellous bone graft, and/or demineralized allograft bone with bone marrow aspirate or a bone void filler cleared for use in intervertebral body fusion to facilitate fusion. These implants may be implanted via an open or a minimally invasive posterior approach and/or transforaminal approach.
The Adaptix™ Interbody System with Titan nanoLOCK™ Surface Technology consists of Additively Manufactured (AM) titanium spacers of various lengths, and heights to accommodate patient anatomy. These devices can be inserted between two lumbar or lumbosacral vertebral bodies to give support and correction during lumbar interbody fusion surgeries. The open geometry of the implants allows them to be packed with autograft bone and/or allograft bone graft comprised of cancellous and/or corticocancellous bone graft, and/or demineralized allograft bone with bone marrow aspirate or a bone void filler cleared for use in intervertebral body fusion to facilitate fusion. The Adaptix™ Interbody System with Titan nanoLOCK™ Surface Technology in intended for use with supplemental fixation systems cleared for use in the lumbar spine.
The subject Adaptix™ Interbody System Fusion devices are available in a variety of lengths and heights for treatment in lumbar interbody fusion procedures. The subject device is designed with a large hollow region in the center to house autograft or allograft bone comprised of cancellous and/or corticocancellous bone and/or demineralized allograft bone with bone marrow aspirate or a bone void filler cleared for use in intervertebral body fusion to facilitate fusion. The design incorporates "honeycomb windows" through the interbody device to permit bone growth through the implant. The new bone formation through the Interbody Device is intended to provide long-term structural support and fusion at the implanted disc space. The Interbody Device incorporates Titan Surface Technologies™ including a macro-rough surface on the superior and inferior surfaces of the device along with the entire device being treated with nanoLOCK™ Surface Technology (MMN™) to improve fixation to the adjacent bone. The nanoLOCK™ Surface Technology (MMN™) provides a microscopic roughened surface with nano-scale features.
The subject device is manufactured from Titanium-6 Aluminum-4 Vanadium Extra Low Interstitial (Ti-6Al-4V ELI) powder in accordance with ASTM F3001: Standard specification for additive manufacturing titanium-6 aluminum-4 vanadium ELI (Extra Low Interstitial) with powder bed fusion.
This 510(k) clearance letter is for the Adaptix™ Interbody System with Titan nanoLOCK™ Surface Technology, which is an intervertebral body fusion device. This type of device is a physical implant designed to facilitate spinal fusion in patients with Degenerative Disc Disease (DDD).
Crucially, this document describes a medical device (an implant), not a software or AI-driven diagnostic/therapeutic device.
Therefore, most of the requested information regarding acceptance criteria and study design for AI/software devices (such as sample sizes for test/training sets, expert adjudication, MRMC studies, standalone algorithm performance, and ground truth establishment for AI models) is not applicable to this 510(k) submission.
The "performance data" section in this document refers to the data demonstrating the safety and effectiveness of the physical implant, which typically involves mechanical testing, biocompatibility testing, material characterization, and comparison to predicate devices, rather than clinical performance data from a diagnostic algorithm.
Here's how to interpret the provided document in the context of your request:
Key Takeaway from the Document:
The current 510(k) submission (K250669) is not for a new device design or new technology assessment, but rather to expand the indications for use of an already cleared physical implant (Adaptix™ Interbody System with Titan nanoLOCK™ Surface Technology, K201267) to include the use of bone void fillers as an additional graft option.
The core argument for clearance is substantial equivalence to existing predicate devices, arguing that the expanded use does not introduce new safety or effectiveness concerns, as bone void fillers are widely used and the primary predicate device is already cleared.
Given this understanding, here's an attempt to answer your questions based on the provided text, highlighting where the information is not applicable due to the nature of the device:
1. A table of acceptance criteria and the reported device performance
Acceptance Criteria (Implicit for this type of device and submission):
For an interbody fusion device, the acceptance criteria typically revolve around:
- Biocompatibility: The material (Ti-6Al-4V ELI) must be biocompatible and safe for long-term implantation.
- Mechanical Strength/Durability: Ability to withstand physiological loads, prevent subsidence, and maintain stability. This is typically demonstrated through static and fatigue testing.
- Pore Size/Osteoconductivity: The design (e.g., "honeycomb windows," macro-rough and nanoLOCK™ surfaces) should facilitate bone ingrowth and fusion.
- Substantial Equivalence: The device must be demonstrated to be as safe and effective as predicate devices. For this specific submission, the crucial acceptance criterion is that adding bone void fillers does not negatively impact the safety or effectiveness of the pre-existing device.
Reported Device Performance (as described in the 510(k) Summary):
The document explicitly states:
"The subject Adaptix™ Interbody System devices do not require any additional data to support their expanded use with bone void fillers to facilitate intervertebral body fusion. This submission does not contain any new or modified implants since the original 510(k) clearance (K201267, S.E. 08-26-2020)."
"The overall design and dimensions of the subject devices are within the established size range of the predicate devices, ensuring compatibility and consistency in performance."
"The inclusion of bone void fillers as an additional graft option does not introduce new safety or effectiveness concerns. Bone void fillers are widely used in spinal fusion procedures and have been demonstrated to be safe and effective promoting bone growth and fusion."
Therefore, the "performance" demonstrated for this specific submission is that the device, when used with bone void fillers, maintains its established safety and effectiveness profile, relying on the prior clearance of the device itself and the known safety/effectiveness of bone void fillers.
2. Sample size used for the test set and the data provenance
- Not Applicable: This is a physical implant device seeking expanded indications based on substantial equivalence, not an AI/software device requiring a clinical test set from patient data. The "test set" would have referred to mechanical testing and material characterization, which are not detailed here beyond stating the device is made from Ti-6Al-4V ELI in accordance with ASTM F3001.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not Applicable: No "ground truth" in the AI/ML sense (e.g., labeling of medical images) is established for an implant device. Clinical efficacy is ultimately determined by fusion rates and patient outcomes in clinical trials, but this 510(k) relies on substantial equivalence and previous data.
4. Adjudication method for the test set
- Not Applicable: No diagnostic interpretations requiring adjudication are involved.
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 refers to AI-assisted diagnostic studies, which are not relevant to this physical interbody fusion device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not Applicable: This refers to the performance of an AI algorithm, not relevant to this physical implant.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not Applicable in the AI/ML sense. For a physical implant, "ground truth" relates to successful fusion (bone growth) and clinical outcomes (pain reduction, functional improvement). This is typically established through radiographic evidence (CT scans, X-rays to confirm fusion), clinical examinations, and patient-reported outcomes from clinical studies, often comparing to a control or predicate. However, in this specific 510(k), the "ground truth" for the expanded use with bone void fillers is the established safety and effectiveness of bone void fillers themselves, and the prior data supporting the device's original clearance.
8. The sample size for the training set
- Not Applicable: No AI/ML training set is involved.
9. How the ground truth for the training set was established
- Not Applicable: No AI/ML training set is involved.
Summary for this specific 510(k) (K250669):
The submission is for an expanded indication for use of an already cleared spinal interbody fusion device (Adaptix™ Interbody System). The "acceptance criteria" and "study" are implicitly tied to demonstrating that the addition of bone void fillers as a graft option does not compromise the device's established safety and effectiveness.
The "study" that proves the device meets the "acceptance criteria" for this specific submission is a demonstration of substantial equivalence by:
- Asserting that no new or modified implants are introduced.
- Confirming the overall design and dimensions are consistent with predicate devices.
- Citing the widespread use and established safety/effectiveness of bone void fillers in spinal fusion.
- Pointing out that the language for bone void fillers mirrors that of other cleared predicate devices.
This 510(k) is a regulatory update based on existing knowledge and established practices, rather than the presentation of novel clinical study data for a new device or an AI algorithm.
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(88 days)
Atlantis® Abutments in Titanium
The Atlantis Abutment and Atlantis Abutment Milling are intended for use with an endosseous implant to support a prosthetic device in a partially or completely edentulous patient. It is intended for use to support single and multiple tooth prosthesis, in the mandible or maxilla. The Atlantis Abutment screw is intended to secure the Atlantis Abutment to the endosseous implant.
The Atlantis Crown Abutment is intended for use with an endosseous implant to function as a substructure that also serves as the final restoration, in a partially or completely edentulous patient. The Atlantis Abutment screw is intended to secure the Atlantis Crown Abutment to the endosseous implant.
The Atlantis Conus Abutment is intended for use with an endosseous implant to support a prosthetic device in partially or completely edentulous patients. It is intended for use to support a removable multiple tooth prosthesis, in the mandible or maxilla. The prosthesis is an attachment- retained by friction fit to the abutment. The Atlantis Abutment screw is intended to secure the Atlantis Conus Abutment to the endosseous implant.
The Atlantis Healing Abutment is intended for use with an endosseous implant for temporary use during soft tissue healing after one-stage or two-stage surgeries. The Atlantis Abutment screw is intended to secure the Atlantis Healing Abutment to the endosseous implant.
Atlantis® Abutment in Titanium refers to the following abutments that are the subject of this 510(k):
- Atlantis® Abutment,
- Atlantis® Crown Abutment,
- Atlantis® Conus Abutment, and
- Atlantis® Healing Abutment.
The Atlantis® Abutments in Titanium are patient-specific dental abutments that are intended for attachment to dental implants in the treatment of partially or totally edentulous jaws for the purpose of restoring chewing function. The design of the Atlantis® Abutments in Titanium is derived from patient dental models and is completed by Dentsply Sirona using computer-assisted design (CAD) technology according to the clinician's prescription. The final CAD design of the Atlantis® Abutment in Titanium is fabricated using computer-assisted manufacturing (CAM) to produce a customized, patient-specific device. Design and fabrication of the Atlantis® Abutment in Titanium is completed in internal Dentsply Sirona manufacturing facilities.
Alternatively, the CAD design, according to the clinician's prescription, can be performed by a laboratory or clinician in an FDA cleared abutment design software (3Shape Abutment Designer Software, K151455) within the design envelope of the Atlantis® Abutments which is codified in the validated and locked design library of the cleared software. Fabrication of the Atlantis® Abutment is then completed in internal Dentsply Sirona manufacturing facilities.
The Atlantis® Abutment in Titanium serves as a connection of the prosthetic construction and the endosseous implant. The lower part of the abutment is designed to fit with the specific implant geometry it is compatible, and the upper part design is according to the patient's specific anatomy. The Atlantis® Abutment in Titanium, including the Conus abutments and Healing abutments, are available in Titanium or Gold-shaded Titanium (titanium nitride layer applied using PVD (Physical Vapor Deposition)). The Crown Abutment is only available in Titanium.
The Atlantis® Abutment design envelope became the basis for the other more specific designs that make up the Atlantis® Abutments in Titanium. The Atlantis® Abutment is intended for use with an endosseous implant and for single tooth restoration.
The Atlantis® Crown Abutment in Titanium incorporates a design that is a combination of an abutment and an anatomically accurate crown to constitute the final finished device. It functions as a substructure that also serves as the final abutment, in a partially or completely edentulous patient.
The Atlantis® Conus abutment supports a removable prosthesis (bridges and overdentures) which is retained by friction fit to the abutment. The abutment connects to the prosthesis via caps embedded in the prosthesis.
The Atlantis® Healing Abutment is used with the compatible implants for temporary use during soft tissue healing after one-stage and two-stage surgeries. It is designed based on the planned final Atlantis® Abutment or Atlantis® Crown Abutment, using the same emergence profile as those abutments to achieve an aesthetic outcome during the soft tissue healing phase.
Unless otherwise noted in this summary, the design envelope has remained unchanged from the previously cleared systems. Parameters such as gingival height and abutment diameter are dependent on the different implant system compatibilities.
The provided document is an FDA 510(k) clearance letter for Atlantis® Abutments in Titanium. This document indicates that the device has received clearance and is considered substantially equivalent to previously marketed devices. However, it is not a clinical study report and therefore does not contain the detailed information typically found in a study that proves a device meets acceptance criteria derived from a clinical trial.
Specifically, the document primarily focuses on non-clinical testing (e.g., MRI compatibility, biocompatibility, reprocessing, and CAD/CAM software validation) to support a labeling change and the substantial equivalence to predicate devices. It explicitly states:
- "8. Clinical Tests Summary and Conclusion: Not applicable. There are no clinical tests submitted, referenced, or relied on in the 510(k) for a determination of substantial equivalence."
Therefore, I cannot extract the requested information (Acceptance Criteria Table, Sample Size, Data Provenance, Ground Truth Experts, Adjudication Method, MRMC Study, Standalone Performance, Ground Truth Type, Training Set Size, Training Set Ground Truth Establishment) from this document as it pertains to a clinical study proving device performance against acceptance criteria.
The information from the document that is relevant to non-clinical testing and device characteristics is provided below.
Non-Clinical Testing and Device Characteristics from the 510(k) Clearance Letter
While a clinical study proving performance against acceptance criteria is not presented, the document does describe the non-clinical tests performed to support the device's safety and effectiveness and its substantial equivalence to predicate devices.
1. A table of acceptance criteria and the reported device performance:
Since this is a 510(k) clearance notice based on substantial equivalence and non-clinical testing, there isn't a direct "acceptance criteria table" in the traditional sense of a clinical trial's performance endpoints. However, the document outlines standards and guidance documents used as criteria for the non-clinical tests, and the stated conclusion is that the device meets these requirements.
Test Category | Acceptance Criteria (Standards/Guidance Fulfilled) | Reported Device Performance (Conclusion stated) |
---|---|---|
MR Safety | - ASTM F2052-21: Measurement of magnetically induced displacement force |
- ASTM F2213-17: Measurement of magnetically induced torque
- ASTM F2119-07 (2013): Evaluation of MR image artifacts from passive implants
- ASTM F2503-20: Marking medical devices for MR safety
- FDA guidance: "Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment" (October 10, 2023) | MR Conditional. Testing included in reference device (K221094) supports labeling update.
The proposed Atlantis® Abutments in Titanium meet the requirements. |
| Biocompatibility | - ISO 10993-1:2018: Biological evaluation of medical devices – Part 1 - ISO 10993-5:2009: Cytotoxicity testing | Biocompatibility assessment was performed and no new questions regarding biocompatibility are raised. Cytotoxicity testing was performed. |
| Reprocessing (Sterilization Drying Time) | - ANSI/AAMI/ISO 17665-1:2006/(R)2013, Annex D - ANSI/AAMI/ISO 14937:2009/(R)2013, Annex D (Approach 3)
- AAMI TIR12:2020
- ANSI/AAMI/ISO TIR17665-2:2009
- FDA guidance: "Reprocessing Medical Device in Health Care Settings: Validation Methods and Labeling" | Reprocessing testing was performed to validate the proposed drying time for steam sterilization. The sterilization drying time validation followed the FDA guidance and relevant standards. |
| CAD/CAM Software Validation & Verification (Atlantis® Abutment Milling) | To ensure that the same design limitations/constraints present in the 3Shape Atlantis® Abutment library match those in the internal CAD system, and that the design parameters cannot be exceeded. | Software validation was performed and confirmed that the additional option of using the 3Shape design module for design of Atlantis® Abutments does not raise new questions of safety and performance as it was confirmed that the locked design library has the same design limits as the internal VAD software. |
| Mechanical Performance (Fatigue Testing) | - ISO 14801:2016: Implants – Dynamic loading test for endosseous dental implants - FDA Guidance: Root-form Endosseous Dental Implants and Endosseous Dental Abutments – Class II Special Controls Guidance Document. | The internally documented and proposed modifications did not affect the performance of the devices and no new fatigue testing was needed. The abutments continue to meet the requirements. |
2. Sample size used for the test set and the data provenance:
- Sample Size for Non-Clinical Tests: Not explicitly stated as numerical sample sizes (e.g., 'n=X implants'). The testing refers to meeting standard requirements (e.g., ASTM, ISO guidelines), which imply specific numbers of test units, but these are not provided in this summary document.
- Data Provenance: The testing was conducted by Dentsply Sirona (the manufacturer) and references previous FDA clearances (K numbers) and established standards. The data is part of the 510(k) submission to the FDA. The provenance of specific raw data (country of origin, retrospective/prospective) is not detailed in this summary.
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 document does not describe a process for establishing ground truth using human experts for the purpose of validating an AI/software device's diagnostic performance against human readers. The validation activity for the software (Atlantis® Abutment Milling) was to ensure its design limitations mirrored the internal CAD system and did not fall outside acceptable parameters.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. This is not a clinical study involving human interpretation or adjudication of findings.
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:
- No. The document explicitly states: "Clinical Tests Summary and Conclusion: Not applicable. There are no clinical tests submitted, referenced, or relied on in the 510(k) for a determination of substantial equivalence." Therefore, no MRMC study was conducted or reported.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- The "software validation" for "Atlantis® Abutment Milling" is a form of standalone performance evaluation for the CAD capabilities. It confirms that the software's design outputs (e.g., abutment geometry) from the 3Shape Abutment Designer Software conform to the established design envelope and limitations of Dentsply Sirona's internal CAD system (Virtual Abutment Design - VAD). This is a technical validation of the algorithm's design capability, not a diagnostic performance study.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For the MR Safety testing, the ground truth or "reference standard" is the physical behavior of the device under MR conditions, measured against established ASTM standards and FDA guidance.
- For Biocompatibility, the ground truth is the biological response, evaluated against ISO standards.
- For Reprocessing, the ground truth is the effectiveness of sterilization and drying, validated against AAMI/ISO standards and FDA guidance.
- For CAD/CAM Software Validation, the "ground truth" for the 3Shape software is the "validated and locked design library" and "design limitations" of Dentsply Sirona's internal VAD software, ensuring the external software produces designs within the company's approved specifications.
- For Mechanical Performance (Fatigue Testing), the ground truth is the structural integrity and durability under dynamic loading, evaluated against ISO standards and FDA guidance.
8. The sample size for the training set:
- Not applicable. This is not an AI/ML device that requires a "training set" in the context of supervised learning for diagnostic tasks. The software referred to (3Shape Abutment Designer Software) is a CAD software for design, not a machine learning model for prediction or classification.
9. How the ground truth for the training set was established:
- Not applicable, as there is no "training set" in the machine learning sense described in this document. The "ground truth" for the CAD software's validation was its adherence to the manufacturer's established design rules and limitations.
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(30 days)
TITANEX Screw Systems
The TITANEX® Screw Systems are indicated for fracture fixation, osteotomies, reconstruction procedures and arthrodesis of bones in the foot and ankle.
The TITANEX® Screw Systems contain cannulated bone screws and general instrumentation as a reconstruction solution for foot and ankle applications. The screws are provided in various diameters and lengths with headed, headless, partially, and fully threaded configurations. The implants are composed of titanium alloy. The instrumentation are composed of stainless steels. The devices are provided non-sterile and are intended to be steam sterilized prior to use.
I am sorry, but the provided text from the FDA 510(k) Premarket Notification does NOT contain information about acceptance criteria or a study proving that a device meets acceptance criteria for an AI/ML-based medical device.
The document pertains to the "TITANEX® Screw Systems," which are metallic bone fixation fasteners, and focuses on demonstrating substantial equivalence to already marketed predicate devices. The non-clinical tests performed (e.g., torsional properties, driving torque, axial pullout strength, sterilization, biological evaluation) are typical for mechanical orthopedic implants.
Therefore, I cannot fulfill your request for:
- A table of acceptance criteria and reported device performance.
- Sample size and data provenance for a test set.
- Number and qualification of experts for ground truth.
- Adjudication method.
- MRMC comparative effectiveness study results.
- Standalone AI performance.
- Type of ground truth used (e.g., pathology, outcomes data).
- Training set sample size.
- Ground truth establishment method for the training set.
This information is not present in the provided document because the device in question is a physical orthopedic implant, not an AI/ML-based diagnostic or therapeutic device.
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(73 days)
Titanium Flexible Geometry FSD Applicator Set (GM11013400)
The Titanium Flexible Geometry FSD Applicator Set with the optional interstitial ovoids is intended for cancer treatment of the uterus, cervix, paracervix, endometrium and vaqina, with intracavitary or with a combination of intracavitary and interstitial HDR brachytherapy.
The Titanium Flexible Geometry FSD Applicator Set with the optional interstitial ovoids is intended for cancer treatment of the uterus, cervix, paracervix, endometrium and vagina, with intracavitary or with a combination of intracavitary and interstitial HDR brachytherapy.
The device does not contain or consist of software/firmware. The device does not contain any biologics or drug components. The device has patient-contacting materials. The device is designed for repeated use. No parts of the system are provided sterile. The device can be steam sterilized with common parameters using pre-vacuum sterilization.
The intended patient population includes adult female patients whose cancer can be treated using HDR brachytherapy, as determined by the prescribing physician. The subject device is intended to be used in a healthcare or treatment facility by trained and qualified personnel.
The key performance characteristics of this applicator set are as follows:
- . The ability to customize the relative depth of the tandem and ovoids, as well as adapt to different anatomies with three tandem angles (15°, 30°, 45°) and a movable cervical stop.
- 3.5 mm diameter intrauterine tandems allow for easy insertion into the cervical channel helping provide maximum patient comfort.
- The tandems and the pivot assembly are made from strong, lightweight titanium.
- Four different ovoid sizes to allow for varying anatomy.
- . Channel marking on the intrauterine tandems and colpostat tandems for easy identification.
- . Ability to image the patient using CT imaging.
- Ability to image the patient using MR imaging.
- Optional interstitial ovoids for more complex cases with guide tubes to allow for the needles to be preloaded outside of the patient and locked into place.
- . Compatible with cervical sleeves to allow easy multiple fraction and help provide maximum patient comfort and eliminate the risk of perforation.
- Can be manually or machine cleaned, disinfected and steam sterilizable.
- Can be securely connected to the BRAVOS Afterloader System and GammaMedeplus iX series afterloader.
- Suitable for patient contact for a period of less than 30 days
This document is a 510(k) Premarket Notification for the Titanium Flexible Geometry FSD Applicator Set (GM11013400). It does not describe an AI/ML powered device. The information provided focuses on the substantial equivalence to a predicate device through non-clinical performance testing. Therefore, many of the requested categories related to AI/ML device studies (such as MRMC studies, standalone algorithm performance, AI training/test sets, expert ground truth establishment, etc.) are not applicable to this submission.
Here is the information that can be extracted relevant to the performance and acceptance criteria for this medical device:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Criteria/Tests Conducted | Reported Device Performance (Summary) |
---|---|---|
Biocompatibility | ISO 10993-1 and applicable parts | Compatibility of skin-contact component material meets biocompatibility requirements. |
Magnetic Resonance (MR) Compatibility | ASTM F2503-23 (Marking) | MR Conditional; complies with standards for marking, RF induced heating, magnetically induced displacement force, torque, and image artifacts. |
ASTM F2182-19e2 (RF Heating) | ||
ASTM F2052-21 (Displacement Force) | ||
ASTM F2213-17 (Torque) | ||
ASTM F2119-07 (2013) (Image Artifacts) | ||
Cleaning, Disinfection, Sterilization | Demonstrated effectiveness for components and specified number of uses | Testing conducted to demonstrate effective sterilization and multi-use capability. |
Human Factors/Usability | IEC 62366 (Human Factors Validation Study) | Device performs well as intended for intended users, uses, and use environments. |
Mechanical & Acoustic Testing | Formal Design Verification & Validation Testing (21 CFR §820, ISO 13485, ISO 14971) | Device performs as intended; conformance to applicable requirements and hazard safeguards. |
Safety & Efficacy | Conformance to FDA-recognized consensus standards (various ISO and EN ISO standards, e.g., ISO 13485, ISO 14971, ISO 10993, IEC 60601) | Demonstrated through verification and validation, meeting safety and performance criteria. |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: Not applicable. This submission concerns a physical medical device (applicator set), not an AI/ML model for data-driven analysis. Performance testing likely involved physical prototypes or units, but specific "sample sizes" in the context of data analysis are not presented.
- Data Provenance: Not applicable in the context of clinical data used for AI/ML development. The testing described is non-clinical (biocompatibility, MR compatibility, cleaning/sterilization, mechanical, human factors).
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- Not applicable. Ground truth as typically defined for AI/ML (e.g., expert labels on medical images) is not relevant for the type of device and testing described. The "ground truth" for this device's performance is established by objective engineering and safety standards.
4. Adjudication Method for the Test Set
- Not applicable. Adjudication is typically for resolving discrepancies in expert labels for AI/ML ground truth.
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
- No. This is not an AI-powered device.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
- No. This is not an AI-powered device.
7. The Type of Ground Truth Used
- The ground truth for this device's performance is based on objective engineering standards, regulatory requirements, and validated test methods. This includes:
- Compliance with ISO 10993 for biocompatibility.
- Compliance with ASTM standards for MR compatibility.
- Demonstrated effectiveness for cleaning, disinfection, and sterilization.
- Usability verification through human factors studies (IEC 62366).
- Verification and validation against design specifications and risk management (21 CFR §820, ISO 13485, ISO 14971).
8. The Sample Size for the Training Set
- Not applicable. This is not an AI/ML device.
9. How the Ground Truth for the Training Set was Established
- Not applicable. This is not an AI/ML device.
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(133 days)
Titanium Fletcher-Style Applicator Set Defined Geometry; Smit Cervical Sleeve
The Titanium Fletcher-style Applicator Set - Defined Geometry is indicated for use for cancer treatment of the uterus, cervix, paracervix, endometrium and vagina using HDR or PDR brachytherapy.
The Smit Cervical Sleeves are indicated for use where any intrauterine tandem is used for HDR or PDR brachytherapy.
The Titanium Fletcher-style Applicator Set – Defined Geometry is intended for use for cancer treatment of the uterus, cervix, paracervix, endometrium and vagina when performing HDR or PDR brachytherapy.
The device does not contain or consist of software/firmware. The device does not contain any biologics or drug components. The device has patient-contacting materials. The device is designed for repeated use. No parts of the system are provided sterile. The device can be steam sterilized with common parameters using pre-vacuum sterilization.
The Titanium Fletcher-Style Applicator Set Defined Geometry includes patients whose cancer can be treated using HDR or PDR brachytherapy, as determined by the prescribing physician. The Titanium Fletcher-Style Applicator Set Defined Geometry is intended to be used in a healthcare or treatment facility by trained and qualified personnel.
This 510(k) submission is also inclusive of the Smit Cervical Sleeve which is an optional component that may be used with the Titanium Fletcher Style Applicator Set Defined Geometry but is not required to successfully perform the intended use.
The provided text describes a 510(k) premarket notification for a medical device, the "Titanium Fletcher-Style Applicator Set Defined Geometry" and "Smit Cervical Sleeves" by Varian Medical Systems, Inc. This document focuses on demonstrating substantial equivalence to a previously cleared predicate device, rather than proving that a new AI/software-based device meets specific acceptance criteria through a clinical study.
The acceptance criteria and study information requested in your prompt (e.g., sample size for test sets, data provenance, number of experts for ground truth, MRMC study, standalone performance, ground truth types for training/test sets) are highly relevant for AI-powered medical devices (software as a medical device - SaMD). However, this 510(k) submission is for a physical medical device used in brachytherapy, not an AI or software device.
Therefore, many of the specific questions in your prompt are not applicable to this non-AI medical device submission. The document details the device's technical specifications, intended use, indications for use, and a comparison to a predicate device to argue for substantial equivalence. The "performance testing" mentioned is primarily non-clinical (biocompatibility, MR compatibility, cleaning/sterilization, human factors, mechanical/acoustic testing), focusing on the device's physical properties and safety, not its diagnostic or therapeutic performance in a statistical sense that would require large clinical studies with ground truth derived from experts or pathology.
Here's a breakdown based on the provided text, addressing the points where information is available and noting where it's not applicable:
Acceptance Criteria and Device Performance (for a non-AI physical device)
The concept of "acceptance criteria" for this type of physical device is framed around demonstrating that its design and performance characteristics are equivalent to or do not raise new questions of safety and effectiveness compared to a legally marketed predicate device. The "performance" is primarily assessed through non-clinical laboratory testing to ensure physical integrity, material compatibility, and functionality within its intended use.
Table of Acceptance Criteria and Reported Device Performance (as inferred for a non-AI device through a 510(k))
Acceptance Criteria Category (Inferred from 510(k) process for physical devices) | Specific Criteria (Implicit for Substantial Equivalence) | Reported Device Performance/Compliance |
---|---|---|
Intended Use & Indications for Use Equivalence | Device's intended use and indications for use are substantially similar to predicate, or differences do not raise new safety/effectiveness questions. Added paracervix. | Claimed: "Although this change adds an additional anatomical site, the manner in which the device is used is consistent with the anatomical area that was originally cleared and does not introduce an additional risk of being used in a generalized treatment application. The overall intended use to treat cancer with brachytherapy is unchanged." (p. 1 |
Material Biocompatibility | Materials are biocompatible for patient contact. | Compliance: Meets ISO 10993-1 and applicable parts. |
MR Compatibility | Device is safe for use in magnetic resonance environments. | Compliance: MR Conditional; complies with ASTM F2503-23. |
Cleaning, Disinfection, and Sterilization (CDS) | Device can be effectively cleaned, disinfected, and sterilized; maintains integrity over specified cycles. | Demonstrated: Testing conducted to show effective sterilization and durability for specified cycles (e.g., sterilization cycle updated to 250 & 500 times from 100 & 500 times). |
Human Factors/Usability | Device performs as intended for intended users, uses, and use environments. (Non-clinical validation) | Demonstrated: Human factors validation study conducted per IEC 62366. |
Mechanical Integrity/Performance | Device maintains structural integrity and performs its mechanical functions as designed. | Demonstrated: Formal design validation testing, design verification testing, and design validation testing confirming performance as intended, in accordance with FDA QSR (21 CFR §820), ISO 13485, and ISO 14971. |
Compatibility with Afterloaders | Device is compatible with specified brachytherapy afterloaders. | Confirmed: Compatible with GammaMedplus Series, VariSource Series, and addition of BRAVOS Afterloader System. |
Safety Standards Compliance | Device conforms to relevant safety and performance consensus standards. | Compliance: Utilized FDA-recognized voluntary consensus standards including ISO 13485, ISO 14971, ISO 15223-1, ISO 20417, IEC 62366-1, ISO 11737-2, ISO 17664-1, ISO 11607-1, ISO 17665-1, various ISO 10993 parts, EN 60601-1, and EN 60601-2-17. (p. 10-11) |
Study Information (as applicable to a non-AI physical device 510(k) submission):
-
Sample size used for the test set and the data provenance:
- N/A (for clinical performance data): This is a submission for a physical device, not an AI/software device requiring a clinical test set for performance evaluation (e.g., diagnostic accuracy). The "testing" refers to non-clinical lab tests (biocompatibility, MR, mechanical, sterilization, human factors).
- For the non-clinical tests (e.g., sterilization cycles, human factors study), the sample size would be determined by the specific ISO/ASTM standards referenced, but typically isn't a large "test set" in the sense of clinical cases. The document does not specify these sample sizes.
- Data Provenance: Not applicable in the context of clinical data for a physical device. Testing is conducted in a laboratory environment, not on patient data from specific countries.
-
Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- N/A: Ground truth established by medical experts is not listed as a component of this non-AI device's performance testing for 510(k) clearance. The device's "performance" is assessed through engineering testing against physical and safety standards and comparison to a predicate.
-
Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- N/A: Not applicable as there is no clinical test set requiring expert adjudication for accuracy or performance.
-
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:
- No: This is not an AI-powered device, so an MRMC study comparing human performance with and without AI assistance was not conducted.
-
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- N/A: This is a physical medical device, not an algorithm.
-
The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- N/A: "Ground truth" in the sense of clinical reference standards (pathology, expert consensus) is not applied to this type of 510(k) submission for a non-AI physical device. The "truth" or reference is established by engineering specifications, material standards, and functional test results (e.g., "does it sterilize correctly?", "is it MR compatible?").
-
The sample size for the training set:
- N/A: This is not a machine learning/AI device, so there is no training set in the AI sense.
-
How the ground truth for the training set was established:
- N/A: Not applicable.
In summary: The provided document is a 510(k) letter for a physical brachytherapy applicator set, demonstrating substantial equivalence to a predicate device. The regulatory pathway for such devices involves rigorous non-clinical testing (e.g., material testing, mechanical testing, sterilization validation) and a comparison of technical characteristics to a predicate, rather than large-scale clinical performance studies or AI-specific validation methods outlined in your prompt.
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(64 days)
PYXIS 3D Titanium Cervical Cage system
The GS Medical PYXIS 3D Titanium Cervical Cages indicated for use in skeletally mature patients with degenerative disc disease (DDD) of the cervical spine with accompanying radicular symptoms at one disc level. DDD is defined as discogenic pain with degeneration of the disc confirmed by patient history and radiographic studies. GS Medical PYXIS 3D Titanium Cervical Cages are used to facilitate intervertebral body fusion in the cervical spine at the C3 to C7 disc levels using autograft bone. GS Medical PYXIS 3D Titanium Cervical Cages are to be used with supplemental fixation. Patients should have at least six (6) weeks of non-operative treatment prior to treatment with an intervertebral cage.
The GS Medical PYXIS 3D Titanium Cervical Cage System devices are designed for restoring the height of the intervertebral space after resection of the disc. The intervertebral body fusion devices are made of 3D printed titanium alloy (Ti-6Al-4V) in accordance with and manufactured as per ASTM F3001. The material and manufacturing process of the subject device, PYXIS 3D Titanium Cervical Cage is identical to the additional predicate (PYXIS 3D Titanium Cage System, K223868). The PYXIS 3D Titanium Cervical Cage System implants are available in various heights, footprints, and lordotic angles to suit the individual patient's pathology and anatomical conditions. The subject device cages ranging in height from 5mm-10mm in 1 mm increments with 0°, 4°, and 8° options. Also in 4.5mm hight for the 0° angle. The cages are provided in three distinct footprints.
This FDA document is a 510(k) premarket notification for a medical device called the PYXIS 3D Titanium Cervical Cage System. It describes the device and claims substantial equivalence to previously cleared predicate devices.
However, the provided text does not contain any information about acceptance criteria or a study that proves the device meets such criteria in the context of an AI/ML powered device, or any kind of AI/ML component at all.
The "PERFORMANCE DATA" section (page 5) simply states that "The worst-case cage of the PYXIS 3D Titanium Cage System underwent testing according to ASTM 2077, specifically static and dynamic axial compression testing, static and dynamic compression shear testing, static and dynamic Torsion testing; expulsion testing, and subsidence testing according to ASTM F2267." These are standard mechanical and structural tests for intervertebral body fusion devices, not performance metrics related to an AI/ML algorithm.
Therefore, I cannot fulfill your request to describe the acceptance criteria and study details for an AI/ML device based on the provided text. The device in question is a purely mechanical implant.
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(104 days)
RibFix Titan Fixation System
The RibFix Titan Fixation System is indicated for the fixation, and fusion of rib fractures and osteotomies of normal and osteoporotic bone.
The Riverpoint Medical RibFix Titan Fixation System is comprised of titanium bone plates that are secured to bone by a deplovable ultra-high molecular weight polyethylene (UHMWPE) suture anchor with a titanium washer and button. Bone plates are provided in configurations for intrathoracic and extrathoracic use. Intrathoracic bone plates are provided in 60mm and 94mm lengths. Extrathoracic bone plates are provided in 60mm, 94mm, and 120mm lengths.
The provided text does not contain detailed acceptance criteria or results of a study proving the device meets those criteria in a tabular format as requested for all points. The document is a 510(k) summary for the RibFix Titan™ Fixation System, which describes performance testing generally but does not provide specific metrics, acceptance criteria, or detailed study results.
However, based on the limited information available, here's what can be extracted:
1. A table of acceptance criteria and the reported device performance:
The document states: "In all instances of the testing referenced above, the acceptance criteria were met, and the proposed RibFix Titan Fixation System performed as intended." However, no specific numerical acceptance criteria or performance metrics are provided in the document.
Acceptance Criteria | Reported Device Performance |
---|---|
Not specified | Met all acceptance criteria |
2. 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 specify sample sizes for mechanical testing or usability validation, nor does it provide information on the data provenance (country of origin, retrospective/prospective).
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. The reported studies are mechanical and usability engineering, not clinical studies requiring expert ground truth for diagnosis/assessment.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
Not applicable. This is not a clinical study involving human judgment on cases.
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 medical device (fixation system), not an AI/software device involving human readers.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
Not applicable. This is a medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
Not applicable. For the mechanical and usability testing mentioned:
- Mechanical testing: Ground truth would be defined by engineering specifications and physical measurements according to standards like ASTM F382 (for plate components) and ASTM F1717 (for assembled constructs).
- Usability engineering validation: Ground truth would be the defined usability goals and safety requirements, assessed through expert evaluation and simulated use.
8. The sample size for the training set:
Not applicable. This is not a machine learning/AI study involving a training set.
9. How the ground truth for the training set was established:
Not applicable. This is not a machine learning/AI study.
Summary of available information regarding studies:
The document mentions the following non-clinical performance data studies were conducted:
- Four-point bend testing (static and fatigue) of bone plate components per ASTM F382.
- Cyclic and Ultimate Tensile Strength (UTS) testing of anchor constructs.
- Cyclic fatigue testing of assembled constructs using ASTM F1717 as a guide.
- Usability engineering validation with simulated use in cadaver lab performed per EN62366-1.
- MR Compatibility testing per ASTM F2052, ASTM F2213, ASTM F2119, ASTM F2182.
The document states that "In all instances of the testing referenced above, the acceptance criteria were met, and the proposed RibFix Titan Fixation System performed as intended." It also mentions that the testing compared the RibFix Titan Fixation System to the predicate device, especially regarding fixation strength. For usability, it notes that the "usability study and performance testing of the RibFix Titan support the use of the RibFix Titan Fixation System and eIFU."
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