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510(k) Data Aggregation

    K Number
    K230591
    Date Cleared
    2023-09-29

    (210 days)

    Product Code
    Regulation Number
    888.3030
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    TriLEAP Plating System

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

    The TRILEAP™ Plating System is indicated for fixation of bones and bone fragments of the foot and ankle in adults and adolescents (aged 12 -21 years) where the growth plates have fused.

    Device Description

    The TRILEAP Plating System is intended for reduction, temporary fixation, fusion and stabilization of bones. The system consists of a family of implantable devices consisting of 2.0mm, 2.5mm, 3.0mm, 3.5mm and 4.0mm non-contoured and anatomic procedure specific plates, cortical screws, and variable angle locking screws available in various sizes.

    AI/ML Overview

    This document describes the FDA's clearance of the TRILEAP Plating System, a metallic bone fixation device. The focus of the provided text is on demonstrating the substantial equivalence of this new device to existing predicate devices through non-clinical performance data, rather than on a study proving the device meets acceptance criteria for an AI/ML powered device.

    Therefore, the requested information regarding acceptance criteria, device performance, sample sizes for test/training sets, data provenance, expert ground truth, adjudication methods, MRMC studies, standalone performance, and ground truth establishment methods for an AI/ML device is not applicable to this submission.

    The provided text only discusses non-clinical performance data for the TRILEAP Plating System as follows:

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

    Test MethodAcceptance CriteriaReported Device Performance
    Plate Cross-Section Analysis (Bending Strength)Not explicitly stated, implied to be comparable to predicate devices.Not explicitly reported, implied to meet equivalence to predicates.
    Screw Torsional Strength Analysis (ASTM F543 via FEA)From FDA Guidance, "Orthopedic Non-Spinal Metallic Bone Screws and Washers – Performance Criteria for Safety and Performance Based Pathway (December 2020)".Not explicitly reported, implied to meet equivalence to predicates.
    Screw Driving Torque (ASTM F543)From FDA Guidance, "Orthopedic Non-Spinal Metallic Bone Screws and Washers – Performance Criteria for Safety and Performance Based Pathway (December 2020)".Not explicitly reported, implied to meet equivalence to predicates.
    Screw Pull-Out (Chapman Equation)Not explicitly stated, implied to be comparable to predicate devices.Not explicitly reported, implied to meet equivalence to predicates.

    Summary of what's not in the document:

    • Sample sized used for the test set and the data provenance: Not applicable.
    • Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable.
    • Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable.
    • 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.
    • If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable.
    • The type of ground truth used (expert consensus, pathology, outcomes data, etc): Not applicable.
    • The sample size for the training set: Not applicable.
    • How the ground truth for the training set was established: Not applicable.

    Explanation of the Study (as described in the document):

    The study was a non-clinical performance evaluation conducted to demonstrate the substantial equivalence of the TRILEAP Plating System to predicate devices. The study involved:

    • Non-clinical Performance Data: The following analyses were conducted:
      • Plate Cross-Section Analysis (Bending Strength)
      • Screw Torsional Strength Analysis according to ASTM F543 via a Finite Element Analysis model
      • Screw Driving Torque according to ASTM F543
      • Screw Pull-Out via the Chapman Equation
    • Acceptance Criteria Source: Screw testing utilized acceptance criteria from the FDA Guidance, "Orthopedic Non-Spinal Metallic Bone Screws and Washers – Performance Criteria for Safety and Performance Based Pathway (December 2020)". For other tests, acceptance was implicitly based on demonstrating similarity or equivalence to the predicate devices.
    • Conclusion: The results of the non-clinical performance data demonstrated that the subject devices are substantially equivalent to the predicate devices, and any differences in technological characteristics do not raise new questions of safety and effectiveness.

    Clinical Performance Data: The document explicitly states: "Clinical testing was not necessary for the determination of substantial equivalence."

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