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510(k) Data Aggregation

    K Number
    K101997
    Date Cleared
    2011-07-12

    (362 days)

    Product Code
    Regulation Number
    888.3020
    Reference & Predicate Devices
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Ellipse Intramedullary Limb Lengthening System is indicated for limb lengthening of the tibia and femurs.

    Device Description

    The Ellipse Intramedullary Limb Lengthening System is composed of a modular implantable intramedullary rod ("Distracting Rod"), locking screws, an external remote controller (ERC), and implantation tools and accessories. The modular implantable rod is available in different configurations, lengths, and diameters to accommodate a variety of patient anatomies. Likewise, the locking screws are available in two different diameters and a variety of lengths from 20 mm to 75 mm in 5 mm increments. The distracting rod is a modular system that includes the IMLL Actuator component and various configurations of IMLL Extension Rods. The IMLL Actuator includes an enclosed rare earth magnet, telescoping lead screw/nut assembly and gearing. The IMLL Actuator is supplied sterile by gamma sterilization while the IMLL Extension Rods, locking screws, and reusable accessories are supplied non-sterile and must be sterilized prior to use.

    AI/ML Overview

    The provided text does not contain detailed acceptance criteria with numerical thresholds, nor does it present specific performance metrics from a study that directly proves the device meets such criteria to the extent that would typically be seen in a clinical trial or performance study report.

    Instead, the document focuses on demonstrating substantial equivalence to a predicate device through various forms of in vitro testing and a comparison of technological characteristics. The "performance" in this context refers to the device successfully passing a series of mechanical, sterilization, biocompatibility, and electrical safety tests, rather than a clinical performance measured against specific clinical acceptance criteria.

    Here's an analysis based on the provided text:

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

    The document lists several tests performed to establish substantial equivalence. While it doesn't explicitly state "acceptance criteria" with numerical values used in the studies, the implicit acceptance criterion for each test is successful completion and compliance with the specified standard.

    Test DescriptionApplicable Test StandardImplied Acceptance CriteriaReported Device Performance
    VDmax25 Gamma Radiation Sterilization ValidationANSI/AAMI/ISO 11137-2: 2007Successfully achieve sterility assurance level (SAL) of 10^-6.Document states "Testing included sterilization," implying successful validation.
    6 month shelf life packaging validationISO 11607Maintain packaging integrity and device functionality for a minimum of 6 months.Document states "shelf life testing for the packaging and the device functionality," implying successful validation.
    Biocompatibility testingISO 10993-1: 2003Demonstrate no unacceptable biological risk when in contact with human tissue.Document states "biocompatibility testing," implying successful compliance.
    External remote controller software validation testingIEC 60601-1-4Software functions as intended and meets safety requirements.Document states "software verification and validations," implying successful.
    External remote controller electrical safety testingIEC 60601-1Meet general safety requirements for medical electrical equipment.Document states "electrical safety testing," implying successful.
    External remote controller electromagnetic interference and compatibility testingIEC 60601-1-2Operate without causing unacceptable electromagnetic interference and without being unduly affected by electromagnetic phenomena.Document states "electromagnetic interference and compatibility testing," implying successful.
    Locking screw Static and dynamic three-point bend testing (Implied for intramedullary rods as well based on standard use)ASTM F1264-03Withstand static and dynamic bending forces as specified by the standard without failure (e.g., fracture, permanent deformation beyond limits).Document lists testing to ASTM F1264-03, implying successful completion to demonstrate equivalence.
    Locking screw axial pullout testingASTM F543-07Withstand specified axial pullout forces without failure.Document lists testing to ASTM F543-07, implying successful completion to demonstrate equivalence.
    Locking screw torque to failureASTM F543-07Withstand specified torsional forces without failure.Document lists testing to ASTM F543-07, implying successful completion to demonstrate equivalence.
    Implantable rod static and dynamic 4-point bend testingASTM F1264-03Withstand static and dynamic bending forces as specified by the standard without failure.Document lists testing to ASTM F1264-03, implying successful completion to demonstrate equivalence.
    Implantable rod torque to failure (Though F543-07 is for bone screws, the context with other rod tests and lack of other rod-specific torque standards suggests it might be referenced for comparative purposes or a related component like the mechanism)ASTM F543-07Withstand specified torsional forces without failure.Document lists testing to ASTM F543-07, implying successful completion to demonstrate equivalence.
    Implantable rod torsional stiffnessASTM F1264-03Exhibit torsional stiffness within acceptable ranges for intramedullary rods.Document lists testing to ASTM F1264-03, implying successful completion to demonstrate equivalence.
    Fixture and device complianceASTM F1264-03Ensure that the testing setup and the device itself adhere to the requirements of the standard during mechanical testing.Document lists testing to ASTM F1264-03, implying successful completion to demonstrate equivalence.
    Safety of magnetic fields (from rare earth magnet and ERC)(Not specified, but internal safety guidelines)Induced magnetic fields are below established safety guidelines.Document states "demonstrated that the induced magnetic fields are below established safety guidelines," implying successful.

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

    • Sample Size: The document does not specify the sample sizes used for each of the mechanical or other in vitro tests. It refers to "testing" performed.
    • Data Provenance: The tests are in vitro tests performed on the device components, not on human or animal subjects. Therefore, there is no country of origin of data or distinction between retrospective/prospective in the clinical sense. These are laboratory tests.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
    This question is not applicable to the type of testing described. The "ground truth" here is the pass/fail criteria defined by the applicable test standards (e.g., ISO, ASTM, IEC). Evaluation of test results against these standards is typically done by engineers or quality control personnel, not medical experts establishing a clinical ground truth.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
    This is not applicable. Adjudication methods like "2+1" or "3+1" are used in clinical studies where multiple experts independently evaluate cases and then resolve discrepancies. The tests mentioned are objective engineering and material science tests, not subjective interpretations requiring medical adjudication.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
    This is not applicable. The device is a mechanical intramedullary limb lengthening system, not an AI-assisted diagnostic or imaging device. Therefore, no MRMC study or AI assistance evaluation was performed.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
    This is not applicable. The device is a physical medical implant with an external remote controller, not a standalone algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
    The "ground truth" for the tests performed is the compliance with recognized international and national standards (e.g., ISO, ASTM, IEC) for mechanical properties, sterility, biocompatibility, electrical safety, and software validation. For the magnetic field safety, it refers to "established safety guidelines." There is no clinical ground truth (like pathology or outcomes data) derived from human subjects for these substantial equivalence tests.

    8. The sample size for the training set:
    Not applicable. There is no training set mentioned, as this is not an AI/machine learning device.

    9. How the ground truth for the training set was established:
    Not applicable, as there is no training set.

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