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510(k) Data Aggregation

    K Number
    K201052
    Manufacturer
    Date Cleared
    2020-08-31

    (132 days)

    Product Code
    Regulation Number
    882.4310
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    PPT

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

    The KLS Martin Individual Patient Solutions (IPS) Planning System is intended for use as a software system and image segmentation system for the transfer of imaging information from a computerized tomography (CT) medical scan. The input data file is processed by the IPS Planning System and the result is an output data file that may then be provided as digital models or used as input to a rapid prototyping portion of the system that produces physical outputs including anatomical models, guides, and case reports for use in the marking and cutting of cranial bone in cranial surgery. The IPS Planning System is also intended as a pre-operative software tool for simulating / evaluating surgical treatment options. Information provided by the software and device output is not intended to eliminate, replace, or substitute, in whole or in part, the healthcare provider's judgment and analysis of the patient's condition.

    Device Description

    The KLS Martin Individual Patient Solutions (IPS) Planning System is a collection of software and associated additive manufacturing (rapid prototyping) equipment intended to provide a variety of outputs to support reconstructive cranial surgeries. The system uses electronic medical images of the patients' anatomy (CT data) with input from the physician, to manipulate original patient images for planning and executing surgery. The system processes the medical images and produces a variety of patient specific physical and/or digital output devices which include anatomical models, guides, and case reports for use in the marking and cutting of cranial bone in cranial surgery.

    AI/ML Overview

    The provided text is a 510(k) summary for the KLS Martin Individual Patient Solutions (IPS) Planning System. It details the device, its intended use, and comparisons to predicate and reference devices. However, it does not describe specific acceptance criteria and a study dedicated to proving the device meets those criteria in the typical format of a diagnostic AI/ML device submission.

    Instead, the document primarily focuses on demonstrating substantial equivalence to a predicate device (K182889) and leveraging existing data from that predicate, as well as two reference devices (K182789 and K190229). The "performance data" sections describe traditional medical device testing (tensile, biocompatibility, sterilization, software V&V) and a simulated design validation testing and human factors and usability testing rather than a clinical study evaluating the accuracy of an AI/ML algorithm's output against a ground truth.

    Specifically, there is no mention of:

    • Acceptance criteria for an AI/ML model's performance (e.g., sensitivity, specificity, AUC).
    • A test set with sample size, data provenance, or ground truth establishment details for AI/ML performance evaluation.
    • Expert adjudication methods, MRMC studies, or standalone algorithm performance.

    The "Simulated Design Validation Testing" and "Human Factors and Usability Testing" are the closest sections to a performance study for the IPS Planning System, but they are not framed as an AI/ML performance study as requested in the prompt.

    Given this, I will extract and synthesize the information available regarding the described testing and attempt to structure it to address your questions, while explicitly noting where the requested information is not present in the provided document.


    Acceptance Criteria and Device Performance (as inferred from the document)

    The document primarily states that the device passes "all acceptance criteria" for various tests, but the specific numerical acceptance criteria (e.g., minimum tensile strength, maximum endotoxin levels) and reported performance values are generally not explicitly quantified in a table format. The closest to "performance" is the statement that "additively manufactured titanium devices are equivalent or better than titanium devices manufactured using traditional (subtractive) methods."

    Since the document doesn't provide a table of acceptance criteria and reported numerical performance for an AI/ML model's accuracy, I will present the acceptance criteria and performance as described for the tests performed:

    Test CategoryAcceptance Criteria (as described)Reported Device Performance (as described)
    Tensile & Bending TestingPolyamide guides can withstand multiple sterilization cycles without degradation and can maintain 85% of initial tensile strength. Titanium devices must be equivalent or better than those manufactured using traditional methods.Polyamide guides meet criteria. Additively manufactured titanium devices are equivalent or better than traditionally manufactured ones.
    Biocompatibility TestingAll biocompatibility endpoints (cytotoxicity, sensitization, irritation, chemical/material characterization, acute systemic, material-mediated pyrogenicity, indirect hemolysis) must be within pre-defined acceptance criteria.All conducted tests were within pre-defined acceptance criteria, adequately addressing biocompatibility.
    Sterilization TestingSterility Assurance Level (SAL) of 10^-6 for dynamic-air-removal cycle. All test method acceptance criteria must be met.All test method acceptance criteria were met.
    Pyrogenicity TestingEndotoxin levels must be below the USP allowed limit for medical devices that have contact with cerebrospinal fluid (
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    K Number
    K182889
    Manufacturer
    Date Cleared
    2019-07-26

    (284 days)

    Product Code
    Regulation Number
    882.4310
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    PPT

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

    The KLS Martin Individual Patient Solutions (IPS) Planning System is intended for use as a software system and image segmentation system for the transfer of imaging information from a computerized tomography (CT) medical scan. The input data file is processed by the IPS Planning System and the result is an output data file that may then be provided as digital models or used as input to a rapid prototyping portion of the system that produces physical outputs including anatomical models, guides and case reports for use in the marking of cranial surgery. The IPS Planning System is also intended as a pre-operative software tool for simulating surgical treatment options.

    Device Description

    The KLS Martin Individual Patient Solutions (IPS) Planning System is a collection of software and associated additive manufacturing (rapid prototyping) equipment intended to provide a variety of outputs to support reconstructive cranial surgeries. The system uses electronic medical images of the patients' anatomy (CT data) with input from the physician, to manipulate original patient images for planning and executing surgery. The system processes the medical images and produces a variety of patient specific physical and/or digital output devices which include anatomical models, guides, and case reports for use in the marking of cranial bone in cranial surgery.

    AI/ML Overview

    The KLS Martin Individual Patient Solutions (IPS) Planning System is a software system and image segmentation system used for transferring imaging information from a CT scan. The system processes input data to produce output data files, which can be digital models or physical outputs like anatomical models, guides, and case reports for cranial surgery. It is also a pre-operative software tool for simulating surgical treatment options.

    Here's an analysis of the acceptance criteria and supporting studies based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance Criteria CategoryReported Device Performance
    Tensile & Bending TestingPolyamide guides withstand multiple sterilization cycles without degradation and maintain 85% of initial tensile strength after 6 months. Additively manufactured titanium devices are equivalent to or better than traditionally manufactured titanium devices.
    Biocompatibility TestingPolyamide devices meet pre-defined acceptance criteria (cytotoxicity, sensitization, irritation, chemical/material characterization, acute systemic toxicity, material-mediated pyrogenicity, indirect hemolysis). Titanium devices (including acute systemic toxicity, material-mediated pyrogenicity, indirect hemolysis) meet pre-defined acceptance criteria.
    Sterilization TestingAll output devices (polyamide, epoxy/resin/acrylic, titanium) achieve a sterility assurance level (SAL) of $10^{-6}$ using the biological indicator (BI) overkill method for steam sterilization.
    Pyrogenicity TestingDevices contain endotoxin levels below the USP allowed limit for medical devices in contact with cerebrospinal fluid (
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    K Number
    K151285
    Manufacturer
    Date Cleared
    2016-09-23

    (498 days)

    Product Code
    Regulation Number
    882.4310
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    PPT

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

    The 3D Systems, Inc. VSP Cranial System is intended for use as a collection of software to provide image segmentation and transfer of imaging information from a CT based medical scanner. The is processed by the VSP Cranial System and the result is an output data file that may then be provided as digital models or used as input in the production of physical outputs including anatomical models, templates, and surgical guides for use in the marking of cranial bone in cranial surgery.

    Device Description

    The 3D Systems VSP® Cranial System is a collection of Commercial Off-The-Shelf (COTS) software, third party medical device software, and custom software intended to provide a variety of outputs to support cranial reconstructive surgery. The system uses CT based imaging data of the patient's anatomy with input from the physician, to manipulate original patient images for planning and executing surgery. The system produces a variety of patient specific outputs including, anatomical models (physical and digital), surgical templates / guides, and patient specific case reports.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study information for the VSP Cranial System, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    TestAcceptance CriteriaReported Device Performance
    Leveraged from Predicate Device
    Biocompatibility testing(Implied: Meets established biocompatibility standards for medical devices)Not explicitly stated for this device, but leveraged from predicate.
    Cleaning and sterilization testing(Implied: Demonstrates effective cleaning and sterilization methods)Not explicitly stated for this device, but leveraged from predicate.
    Software verification and validation(Implied: Software functions as intended, meets specified requirements, and is safe and effective)Not explicitly stated for this device, but leveraged from predicate.
    Performance testing (Process validation, Simulated Use, Mechanical testing)(Implied: All aspects of the manufacturing process, simulated use in planning, and mechanical strength/durability meet pre-established specifications)Not explicitly stated for this device, but leveraged from predicate.
    Specific to VSP Cranial System
    Packaging ValidationPackaging and labels tested according to ASTM D4577, ASTM D642 (Method A), ASTM D4728, ASTM D3580, ASTM D5276, ASTM D6179, ASTM D880, ASTM D6179, ASTM D6653, and National Motor Freight Classification Rule 180. (Implied: Successfully withstands shipping and handling without compromise to product integrity or labeling)All packaging and labeling met the required acceptance criteria.
    Sterilization CompatibilityVSP® Cranial System outputs subjected to a single sterilization cycle and visually/dimensionally inspected to ensure compatibility with the validated sterilization method. (Implied: Maintains visual and dimensional integrity after sterilization.)All acceptance criteria was met.
    Dimensional AnalysisSizes and shapes of VSP® Cranial System templates and guides (selected to challenge the system) were dimensionally inspected to verify conformance to the product requirements. (Implied: Dimensions are within specified tolerances.)All acceptance criteria was met.
    BioburdenBioburden testing conducted on VSP® Cranial System templates, guides, anatomical models, and metal accessories per ISO 11737-1, USP and USP . (Implied: Bioburden levels are within acceptable limits for sterilization.)All acceptance criteria was met.
    Pyrogenicity testingPyrogenicity testing conducted on VSP® Cranial System templates, guides, anatomical models, and metal accessories per AAMI ST72, USP , and USP . (Implied: Endotoxin levels are below a specified threshold.)All samples met the acceptance criteria of ≤ 2.15 EU/device.

    2. Sample Size Used for the Test Set and Data Provenance:

    The document details performance testing that was largely leveraged from the predicate device (VSP® System, K133907) because the planning/design process, materials, manufacturing process, cleaning methods, and sterilization methods are identical.

    For the tests specific to the VSP Cranial System:

    • Sample Size: Not explicitly stated but "sizes and shapes of VSP® Cranial System templates and guides were selected to challenge the system" for Dimensional Analysis. For bioburden and pyrogenicity, "VSP® Cranial System templates, guides, anatomical models, and metal accessories" were tested.
    • Data Provenance: This appears to be prospective testing conducted by 3D Systems for the specific VSP Cranial System device. The country of origin of the data is not specified beyond being generated by the applicant, 3D Systems, Inc., which is based in Littleton, Colorado, USA.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications:

    This information is not provided in the document. The testing described focuses on engineering, material, and sterilization validation rather than clinical performance or diagnostic accuracy that would require expert-established ground truth for a test set.

    4. Adjudication Method for the Test Set:

    This information is not provided in the document. As mentioned above, the tests are primarily engineering and material validations, which don't typically involve an adjudication method in the way a clinical study for diagnostic accuracy would.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

    No, an MRMC comparative effectiveness study was not done. The study described is not a clinical study involving human readers or comparative effectiveness of AI assistance. It's a technical performance and validation study to demonstrate substantial equivalence to a predicate device.

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

    The device is described as a "collection of software" that provides image segmentation and processing, resulting in an "output data file that may then be provided as digital models or used as input in the production of physical outputs." The system is operated by "trained 3D Systems employees," and the "physician does not directly input information" but provides "clinical input and review."

    While there is "software verification and validation testing" (leveraged from the predicate), the document does not explicitly describe a standalone performance study for the algorithm's output in terms of accuracy against a ground truth independent of the human-in-the-loop (3D Systems employees and physician review) process. The nature of this device (planning tools for customized physical outputs) means the "human-in-the-loop" is integral to its intended use and output generation.

    7. The Type of Ground Truth Used:

    For the specific tests performed:

    • Packaging Validation: Ground truth is defined by the technical specifications of the ASTM and National Motor Freight Classification standards.
    • Sterilization Compatibility: Ground truth is visual and dimensional integrity after a validated sterilization cycle.
    • Dimensional Analysis: Ground truth is the "product requirements" and specified dimensional tolerances.
    • Bioburden: Ground truth is defined by the acceptable bioburden limits specified in ISO 11737-1, USP , and USP .
    • Pyrogenicity: Ground truth is the acceptance criteria of ≤ 2.15 EU/device as per AAMI ST72, USP , and USP .

    For the overall system, the "ground truth" for its functionality is implicitly linked to the predicate device's established performance and safety/effectiveness, as the core technologies and processes are leveraged and deemed "substantially equivalent."

    8. The Sample Size for the Training Set:

    This information is not applicable/not provided. The VSP Cranial System is not described as a machine learning or AI algorithm that requires a "training set" in the conventional sense for developing predictive models. It's a software system for image segmentation and design of physical outputs based on CT data.

    9. How the Ground Truth for the Training Set was Established:

    This information is not applicable/not provided for the same reasons as point 8.

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