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510(k) Data Aggregation
(30 days)
UNIVERSAL TOTAL WRIST SYSTEM
Indicated for intractable pain resulting from traumatic arthritis, osteoarthritis, rheumatoid arthritis, trauma-induced osteoarthritis of the radial/carpal joint. To replace functionality of the joint due to deformity or elements stated above. The Universal Total Wrist is intended for cemented use.
The KMI Universal Total Wrist (UTW) System (both predicate and extra small) consists of the following components: the radial implant, the carpal plate implant, the carpal polymer component, and two bone screws. The system will now be offered in 4 (four) sizes: 'extra small', 'small', 'medium' and 'large'), each with 3 (three) matching polymer component sizes, which are available in yarvina thicknesses (height); standard, +1 and + 2, It is constructed of materials that have a long clinical history of proven acceptance and performance. This system is intended for use with cement and will be promoted as such in the UTW Surgical Protocol.
Here's an analysis of the provided text regarding the Universal Total Wrist System, focusing on acceptance criteria and supporting studies:
Based on the provided documents, this 510(k) submission (K030037) is a Special 510(k) Notification for a modification to an already cleared device, the Universal Total Wrist System. Specifically, it's for introducing an "extra small" size. Special 510(k)s often rely heavily on demonstrating substantial equivalence to a predicate device and may not involve extensive new clinical or performance studies in the same way a novel device might.
Therefore, the concept of "acceptance criteria" and "study proving the device meets the acceptance criteria" in the traditional sense (e.g., performance metrics with defined thresholds for a new device) is not directly applicable or explicitly detailed in these documents for the modified device. Instead, the "acceptance criteria" here are implicitly met by demonstrating substantial equivalence to the predicate device. The "study" is more accurately described as a comparison and analysis against the predicate.
Here's the breakdown of the information as requested, tailored to the context of a Special 510(k) for a size modification:
Acceptance Criteria and Device Performance (Based on Substantial Equivalence)
Acceptance Criteria (Demonstrated Equivalence to Predicate) | Reported Device Performance (Extra Small Universal Total Wrist System) |
---|---|
Identical Design to predicate UTW implants (small, medium, large). | The extra small size has an identical design to the predicate Universal Total Wrist System (K961051, K020554). |
Identical Materials to predicate UTW implants. | The extra small size is constructed of identical materials as the predicate. |
Identical Operating Principle to predicate UTW implants (functioning as a wrist joint metal/polymer prosthesis). | The extra small size has an identical operating principle as the predicate, providing wrist joint replacement. |
Identical Packaging and Sterilization Materials and Processes to predicate UTW implants. | The extra small size is packaged and sterilized using identical materials and processes as the predicate. |
Intended Use consistent with predicate (replacing functionality due to intractable pain from various arthropathies). | The extra small size is indicated for the same intended use as the predicate: intractable pain from traumatic arthritis, osteoarthritis, rheumatoid arthritis, or trauma-induced osteoarthritis of the radial/carpal joint, for cemented use. |
Study Details (Comparison for Substantial Equivalence)
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Sample size used for the test set and the data provenance:
- Test Set: No clinical test set in the traditional sense is described. The "test set" for this submission consists of the engineering drawings and specifications of the "extra small" implant.
- Data Provenance: The comparison is based on the design specifications and material properties of the new "extra small" component and the previously cleared "small" (predicate) component. The provenance is internal manufacturing and design data from Kinetikos Medical, Inc. This is a retrospective comparison against an already cleared predicate device.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- No external experts were explicitly mentioned as being used to establish "ground truth" for this engineering comparison. The "ground truth" for the comparison is the design and material specifications of the predicate device, which were previously reviewed and cleared by the FDA. The manufacturer's internal engineering and quality assurance personnel would have performed the comparison.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- No adjudication method in the context of expert review is described. The comparison relies on documented specifications. The FDA's review process itself acts as an adjudication that the presented information supports substantial equivalence.
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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 device is a mechanical implant (wrist prosthesis), not an AI-powered diagnostic tool. Therefore, an MRMC comparative effectiveness study involving human readers/AI is irrelevant and was not conducted.
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If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- No. This is a physical medical device, not an algorithm.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The "ground truth" for this submission is the already established and FDA-cleared design, material, manufacturing, and performance characteristics of the predicate Universal Total Wrist System. The "extra small" size is demonstrating conformity to these established truths by being "identical" in all key aspects except size.
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The sample size for the training set:
- Not applicable. There is no "training set" as this is not a learning algorithm. The "training" for the predicate device would have involved a long clinical history of similar materials and designs, as explicitly stated: "It is constructed of materials that have a long clinical history of proven acceptance and performance." This refers to general knowledge about medical-grade materials, not a specific training dataset for this device.
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How the ground truth for the training set was established:
- Not applicable. As above, there's no "training set." The "ground truth" for the overall device's safety and effectiveness (as represented by the predicate) was established through previous FDA clearances based on established standards, material properties, mechanical testing, and clinical history of similar devices.
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(72 days)
MODIFICATION TO UNIVERSAL TOTAL WRIST SYSTEM
Indicated for intractable pain resulting from traumatic arthritis, rheumatoid arthritis, trauma-induced osteoarthritis of the radial/carpal joint. To replace functionality of the joint due to deformity or elements stated above. Intended for cemented use only.
The KMI Universal Total Wrist™ (UTW) System (either predicate or modification) consists of the following components: the radial implant, the carpal plate implant, the carpal polymer component and two bone screws. The system is offered in three sizes (small, medium, and large), with three matching polymer component sizes, which are available in varying thicknesses (standard, +1 mm, +2 mm). It is constructed of materials that have a long clinical history of proven acceptance and performance. This system is intended for use with cement and will be promoted as such in the UTW surgical technique manual.
The provided text is a 510(k) summary for a medical device (Universal Total Wrist™ System), not a study report detailing acceptance criteria and performance against those criteria. Therefore, I cannot extract the requested information as it is not present in the provided document.
The document focuses on:
- Administrative information: Manufacturer, contact, device names, predicate device.
- Intended use: Medical conditions for which the device is indicated.
- System description: Components, sizes, and materials.
- Equivalence to marketed product: Claims of similarity to a predicate device.
- FDA clearance letter: Confirmation of substantial equivalence.
- Indications for Use statement: Formal statement of approved uses.
There is no mention of:
- Specific acceptance criteria (numerical thresholds for performance).
- A study proving the device meets acceptance criteria.
- Sample sizes for test or training sets.
- Data provenance, expert qualifications, or adjudication methods for ground truth establishment.
- Comparative effectiveness studies (MRMC) or standalone algorithm performance.
The document describes a modification to an existing device, emphasizing its substantial equivalence to the predicate device based on material composition, intended use, operating principle, and basic design, rather than presenting a performance study with detailed acceptance criteria.
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(87 days)
UNIVERSAL TOTAL WRIST SYSTEM (MODIFICATION)
The KMI Universal Total Wrist™ System is indicated for intractable pain resulting from traumatic arthritis, osteo arthritis, theumatoid arthritis, trauma induced osteo arthritis of the radial / Carpal joint. To replace functionality of the joint due to deformity or elements stated above.
The KM1 will be offered in three sizes (small, medium, and large) with the poly bearing implant also offered in three sizes to match the carpal plate implants. The Universal total Wrist implant is constructed of materials that have a long clinical history of proven acceptance and performance. This system is intended for use with cement and will be promoted as such in the UTW surgical protocol
The provided text describes a medical device, the Universal Total Wrist™ System, and its regulatory submission to the FDA. However, it does not contain information about acceptance criteria for the device's performance in a study, nor does it detail any specific study that proves the device meets such criteria.
The document focuses on:
- Regulatory Information: Company details, classification, and substantial equivalence to other existing devices.
- Device Description: Materials used (meeting ASTM standards), sizes, indication for use, and sterilization methods.
- Performance Standards: It explicitly states, "No performance standards applicable to semi-constrained wrist implant have been established by the FDA." It then mentions that the materials used (titanium alloy, CrCoMo) meet chemical and mechanical requirements in voluntary standards established by the American Society for Testing and Materials (ASTM).
- Summary: Highlights the long clinical history of similar wrist implant systems and the understanding of their uses, indications, and limitations.
Therefore, I cannot provide the requested table or details about a study demonstrating acceptance criteria because this information is not present in the provided text.
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