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510(k) Data Aggregation

    K Number
    K192710
    Manufacturer
    Date Cleared
    2020-06-24

    (271 days)

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

    The Simple Locking Intramedullary (Slim) System

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

    The Simple Locking IntraMedullary (SLIM) System is intended as a temporary implant for alignment, stabilization and fixation of long bones that have been surgically prepared (osteotomy) for correction of deformities, or have sustained fractures due to trauma or disease. This includes:

    • Femur and tibia in the pediation (child and adolescent), and small-stature adults such as patient with small intramedullary canals affected by skeletal dysplasias, osteogenesis imperfecta or other bone diseases.
      . Humerus, ulna, fibula in all patient populations
    Device Description

    The Simple Locking Intra-Medullary (SLM) system consists of intramedullary fixation devices for use in long bones. The solid shaft, bevelled point, and pre-determined or blank length options is designed for easy insertion in the medullar canal. Anchorage of the device is achieved through a conical thread to obtain a stable fixation in the epiphyses or cortical bone, which aims to reduce the risk of migration. Internal features, such as a hexagonal drive and an internal mechanical thread in the device, are designed for capture and guidance during insertion and retrieval. Additional proximal and distal locking holes allow pinning to ensure fixation with locking pegs when required, and the Bullet screws allow fixation of smaller diameter shafts that cannot be cross-pinned due to their size. The SLIM implants are manufactured in medical grade Stainless Steel (SS316L, ASTM F138). The rods are available in seven diameters: 2.0.2.6.3.2. 4.0. 4.8. 5.6 and 6.4 mm, from 80mm up to 400 mm in length allows end user to customize the length of the rod.

    AI/ML Overview

    The provided text describes a medical device's 510(k) submission to the FDA, focusing on substantial equivalence to predicate devices, rather than detailed acceptance criteria and a study proving device performance against such criteria. As such, much of the requested information is not available in the text.

    Here's what can be extracted and what is not available:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance CriteriaReported Device Performance
    Not explicit in textFour-point static bending: Bullet screws found equivalent for intended uses.
    Fatigue four-point bending: Bullet screws found equivalent for intended uses.
    Pull-out & Push-out strength: Not explicitly stated, but performed.
    Migration resistance of Shaft to Bullet assembly (static loading): Performed and evaluated.
    Migration resistance of Shaft to Bullet assembly (cyclic loading/fatigue): Performed and evaluated.
    Comparative loading in physiological relevant setting of SLIM and Bullet against predicate: Performed.
    Functional testing of Intro-OP Implant Cutter (ICON) Prototype on SLIM blank: Performed.
    Mechanical Resistance (SLIM blanks): Same as previously cleared SLIM rodsSLIM blanks: identical diameters and material as previously cleared SLIM rods.
    Mechanical Resistance (Added pins and pegs): Same or higher than previously cleared pinsAdded pins and pegs: same or larger diameter and same material than previously cleared pins.
    Equivalence of locking pegs vs. simple locking pin (torsion, drive torque, axial pull-out): Locking pegs perform equivalentlyLocking pegs: considered to perform equivalently than simple locking pin.

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

    • Sample Size: Not specified for any of the non-clinical tests.
    • Data Provenance: Not specified, but based on the nature of the tests (bench testing, animal model) and the "non-clinical" designation, it would be laboratory-generated data.

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

    • Not Applicable. This submission details non-clinical bench testing and an animal model, not studies requiring expert review for ground truth establishment.

    4. Adjudication method for the test set:

    • Not Applicable. No human-based adjudication methods were mentioned as this was non-clinical testing.

    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, an MRMC study was not done. This is a mechanical device, not an AI-powered diagnostic tool.

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

    • Not Applicable. This device is an implant, not an algorithm.

    7. The type of ground truth used:

    • For the non-clinical tests, the "ground truth" would be established by validated test methodologies and measurements against engineering specifications or comparative performance to predicate devices (e.g., comparing load-bearing capacity, fatigue life, pull-out strength).
    • For the animal model validation, the "ground truth" would be related to successful surgical technique demonstration and expected biological/mechanical outcomes in the animal.

    8. The sample size for the training set:

    • Not Applicable. This device doesn't involve a "training set" in the context of machine learning or AI.

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

    • Not Applicable. (See above)

    Summary of the Study that Proves the Device Meets Acceptance Criteria (based on the provided text):

    The text describes a series of non-clinical, bench-top mechanical tests and validation in an animal model to demonstrate the substantial equivalence of “The Simple Locking IntraMedullary (SLIM) System” to its predicate devices. The primary goal was to ensure that new components (Bullet screws, new pins/pegs, SLIM blanks) and the system as a whole performed equivalently or better than previously-cleared components and predicate devices.

    Key tests performed include:

    • Static four-point bending bench testing
    • Fatigue four-point bending bench testing
    • Pull-out & Push-out strength
    • Surgical technique validation on an animal model
    • Evaluation of Shaft to Bullet assembly migration resistance (static and cyclic loading)
    • Static and fatigue four-point bending of the Bullet screws
    • Comparative loading in a physiologically relevant setting of the SLIM and Bullet against the predicate device
    • Functional testing of a cutting operation for an associated instrument (Intro-OP Implant Cutter (ICON) Prototype).

    The conclusion of these tests was that the Bullet screws were "found equivalent for their intended uses," and the locking pegs were "considered that they perform equivalently" to simple locking pins in terms of torsion, drive torque, and axial pull-out. The SLIM blanks were deemed to have the same mechanical resistance due to identical materials and dimensions, and new pins/pegs were expected to have the same or higher mechanical resistance due to similar or larger diameters and materials.

    No clinical testing was provided as a basis for substantial equivalence. The justification for this device's acceptance relied entirely on these non-clinical performance data and the conclusion that the "anticipated benefits of such a system clearly outweigh the possible residual risks."

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    K Number
    K143355
    Manufacturer
    Date Cleared
    2015-07-10

    (228 days)

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

    The Simple Locking IntraMedullary (SLIM) System

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

    The SLIM System is intended as a temporary implant for alignment, stabilization of long bones that have been surgically prepared (osteotomy) for correction of deformities, or have sustained fractures due to trauma or disease. This includes the femur, tibia, humerus, ulna and fibula of the pediatric population (child and adolescent) , and patients with small intramedulary canals affected by skeletal displasias, osteogenesis imperfecta or other bone diseases.

    Device Description

    The Simple Locking IntraMedullary (SLIM) System consists of intramedullary fixation devices for use in long bones. The solid shaft and bevelled point are designed for quided insertion through the medullary canal. Anchorage of the device is achieved through a conical thread for a wedged fixation in the epiphyses or cortical bone, which aims to reduce the risk of migration. Internal features, such as a hexagonal drive and an internal mechanical thread in the device, allow for capture and quidance during insertion and retrieval. Additional proximal and distal locking holes provide supplementary pinning options when required. The SLIM, single-use, implants are manufactured in medical grade Stainless Steel (SS316L, ASTM F138). The rods are available in seven diameters: 2.0, 2.6. 3.2, 4.0. 4.8, 5.6 and 6.4 mm, from 80mm up to 400 mm in length.

    AI/ML Overview

    The provided document is a 510(k) premarket notification decision letter and summary for a medical device called "The Simple Locking IntraMedullary (SLIM) System." This type of document establishes substantial equivalence to existing devices and generally does not contain detailed acceptance criteria and studies as would be found in a clinical trial report for an AI/CADe device.

    Therefore, many of the requested details, particularly those related to AI/CADe performance metrics, sample sizes for test and training sets, expert qualifications, and ground truth establishment, are not applicable or not present in this document.

    However, I can extract information related to the device's performance based on the non-clinical performance data section, which focuses on mechanical properties.

    Here's a summary of the available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    Since this is a mechanical device, the "acceptance criteria" are related to mechanical properties and equivalence to a predicate device. The document does not explicitly state numerical acceptance criteria in a pass/fail format but rather compares the SLIM system's performance to a predicate.

    Acceptance Criteria (Implied)Reported Device Performance (SLIM System)
    Mechanical properties are equivalent or superior to the predicate device (Synthes SS Elastic Intramedullary Nail System [K081452])."The SLIM system's mechanical properties are superior to that of the Synthes SS Elastic Intramedullary Nail System."
    Static four-point bending bench testing performance is equivalent to the predicate (STEN system)."Results of the static ... four-point bending bench testing on the SLIM and STEN system have demonstrated that the SLIM system performed equivalently as the predicate STEN system."
    Fatigue four-point bending bench testing performance is equivalent to the predicate (STEN system)."Results of the ... fatigue four-point bending bench testing on the SLIM and STEN system have demonstrated that the SLIM system performed equivalently as the predicate STEN system."
    Safety and effectiveness for intended use."As per the findings of the bench testing and the scientific literature review, the data supports the use of this product as safe and effective for its intended use; the anticipated benefits of such a system clearly outweigh the possible residual risks."

    Regarding the other requested information:

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

      • Sample size: Not specified. The studies mentioned are "four-point bending bench testing" on the SLIM system and the STEN system. The number of samples (e.g., number of rods tested) is not provided.
      • Data provenance: Bench testing results. Location of testing and design of the test samples are not mentioned.
    • 3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. The "ground truth" for mechanical testing would be the measured physical properties, not expert consensus.

    • 4. Adjudication method (e.g., 2+1, 3+1, none) for the test set: Not applicable. Mechanical test results do not involve adjudication by experts in this context.

    • 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 device is a physical intramedullary rod, not an AI/CADe system for image interpretation.

    • 6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done: Not applicable. This is not an AI algorithm.

    • 7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): The "ground truth" for the non-clinical performance data was objective mechanical measurements (e.g., strength, fatigue resistance).

    • 8. The sample size for the training set: Not applicable. There is no AI/machine learning component mentioned, thus no training set in the AI sense.

    • 9. How the ground truth for the training set was established: Not applicable.

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