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510(k) Data Aggregation
(510 days)
Merries K-PHATE is intended to be packed into bony defects of the skeletal system ( extremities, spine, or pelvis) which are not intrinsic to the stability of the bony structure. These defects may be surgically created voids or from traumatic injury to the bone. The device gradually resorbs and is replaced with bone during the healing process. Rigid fixation techniques should be used in conjunction with this device.
Merries K-PHATE bone graft substitute is a microporous and macroporous biphasic calcium phosphate ceramic consisting of 60% hydroxyapatite and 40% ß-tricalcium phosphate. Merries K-PHATE is supplied sterile in various shapes and sizes. The choice of different form or size of the product depends on the type and size of the recipient site. Blocks and wedges are used for large bony defect while granules are used as bone filler for small area.
The provided text describes the 510(k) Premarket Notification Summary for the "Merries K-PHATE Bone graft substitute" (K063157). This document focuses on demonstrating substantial equivalence to predicate devices rather than proving the device meets specific performance criteria through a clinical study. Therefore, much of the requested information regarding acceptance criteria, performance metrics, and study design for a clinical effectiveness study is not explicitly present in the provided text.
Specifically, this submission relies on:
- Material characteristics: The device is a biphasic calcium phosphate ceramic, similar to predicate devices.
- Function and intended use: It's designed as a resorbable bone void filler, the same as predicate devices.
- Biocompatibility testing: To ensure safety.
- Sterilization dose auditing: To ensure sterility.
- Chemical requirements: Conformance to ASTM standards for ceramic hydroxyapatite and beta-tricalcium phosphate.
Here's an attempt to answer your questions based on the provided text, recognizing that a full clinical study with acceptance criteria for effectiveness is not detailed:
Acceptance Criteria and Device Performance (Based on provided 510(k) Summary)
Since this is a 510(k) submission for a bone graft substitute, the primary "acceptance criteria" discussed are related to substantial equivalence to legally marketed predicate devices, and the device's safety through biocompatibility and material testing. Performance in terms of clinical outcomes (e.g., rate of bone fusion, strength of new bone) is inferred from the predicate devices rather than directly proven through a new comparative clinical study for this specific device in this submission.
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Criterion | Reported Device Performance |
---|---|---|
Substantial Equivalence | Similarity in base materials, function, and intended use to listed predicate devices. | Stated as "substantially equivalent" in base materials, function, and intended use to MBCP™, Pro Osteon® 500R, Vitoss® Scaffold, and BoneSave™ Bone void Filler. |
Material Composition | Conformance to ASTM F1185-88 (ceramic hydroxyapatite) | Implicitly stated as conforming to ASTM F1185-88. |
Conformance to ASTM F1088-87 (beta-tricalcium phosphate) | Implicitly stated as conforming to ASTM F1088-87. | |
Biocompatibility (ISO 10993 equivalent) | Non-cytotoxic | Pass (Cytotoxicity Test) |
Non-irritant | Pass (Subcutaneous Irritation Test) | |
Non-sensitizing | Pass (Guinea Pig Skin Sensitization Study) | |
Compatible with surrounding tissues | Pass (Implantation Test) | |
Non-mutagenic | Pass (Sister Chromatid Exchange Test) | |
Sterility | Sterilization dose auditing for sterility. | Stated as "Merries K-PHATE has been tested of sterilization dose auditing for sterility." |
Manufacturing & Quality | Good Manufacturing Practice (GMP) | Required by Act (implied by 510(k) clearance) |
Labeling | Conformance to labeling regulations (21 CFR Part 801) | Required by Act (implied by 510(k) clearance) |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The provided summary does not detail a clinical "test set" for performance evaluation in the way a clinical trial would. The "tests" reported are primarily bench/laboratory tests for material properties and biocompatibility.
- Sample Size for Bench/Biocompatibility Tests: Not specified in the summary. These tests typically involve a relevant number of samples for each specific test (e.g., cell cultures for cytotoxicity, animal models for irritation/sensitization/implantation).
- Data Provenance: The manufacturing company is based in Taipei, Taiwan (Merries International Inc.). The specific locations where the individual biocompatibility tests were conducted are not stated, but given the company's location, they were likely performed in a certified lab, potentially in Taiwan or another country as required for international standards. These tests are prospective in nature, conducted specifically for this submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
This information is not applicable as there is no human-read clinical test set described in this summary to establish a "ground truth" for diagnostic or prognostic performance. The "ground truth" for the material and biocompatibility tests is based on objective scientific measurements and established standards (e.g., cell viability, tissue response, chemical composition as per ASTM).
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable. No clinical test set with human assessment requiring adjudication is described.
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. This device is a bone graft substitute, not an AI-powered diagnostic or assistive technology. No MRMC study was conducted or is relevant to this type of device.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
This is not applicable. This device is a bone graft substitute, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the tests conducted:
- Material Composition: Ground truth is based on physical and chemical analysis techniques confirming compliance with ASTM standards.
- Biocompatibility: Ground truth is based on biological assays and histological examination in animal models, evaluated against established criteria for cytotoxicity, irritation, sensitization, and tissue compatibility.
- Sterility: Ground truth is based on microbiological testing (sterilization dose auditing).
There is no "expert consensus" or "pathology" in the sense of a clinical diagnostic study. Outcomes data (e.g., long-term bone healing) would typically be part of a full clinical trial, which is not detailed here for this 510(k) submission.
8. The sample size for the training set
This is not applicable. This device is a medical implant, not a machine learning model, and therefore does not have a "training set."
9. How the ground truth for the training set was established
This is not applicable as there is no training set for this device.
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(203 days)
MBCP™ is intended for use as a bone void filler for bony voids or gaps of the skeletal system (e.g. extremities, spine and pelvis) that are not intrinsic to the stability of the bony structure. MBCP™ can be used with autograft as a bone graft extender. These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone.
MBCP™ is a bone filler without initial mechanical properties. Therefore rigid fixation techniques may often be recommended.
When packed into a bony site, MBCP™ gradually resorbs and is replaced with bone during the healing process.
in addition, when used with appropriate opening osteotomy system devices, plates and screws, MBCP™ is intended to be used as a bone void filler in femoral or tibial osteotomies.
MBCP™ is to be used in association with adequate post-operative immobilization.
MBCP™ is a bone graft substitute. MBCP™ is a microporous and macroporous biphasic calcium phosphate ceramic consisting of 60% Hydroxyapatite (HA) and 40% beta-Tricalcium Phosphate (ß-TCP). MBCP™ is available in various shapes and sizes.
MBCP™ granules are packaged in vials or syringes.
MBCP™ may be used with physiological saline, patient's own serum, whole blood, or bone marrow aspirate (BMA).
MBCP™ is provided sterile for single patient use.
This document is a 510(k) Summary of Safety and Effectiveness for the MBCP™ device. It establishes the device's substantial equivalence to previously cleared devices rather than demonstrating meeting specific acceptance criteria through a new study. Therefore, the information requested regarding a new study showing the device meets acceptance criteria is largely not applicable in this context.
Here's an analysis based on the provided text:
1. Table of acceptance criteria and the reported device performance
This document does not present acceptance criteria and device performance in a tabular format as it's a submission for substantial equivalence, not a report on a new study with specific performance metrics against pre-defined criteria. The primary "acceptance criterion" in a 510(k) is demonstrating substantial equivalence to a predicate device.
The document states:
- "The intended use and material composition of MBCP™ Bone Graft Substitute is the same as previously cleared MBCP™ (K032268, K043005)."
- "MBCP™ Bone Graft Substitute and the predicate devices are substantially equivalent in design, materials of construction and function."
- "The safety and effectiveness of MBCP™ Bone Graft Substitute as modified in this submission is adequately supported by the substantial equivalence information, safety and performance data provided within this Premarket Notification."
2. Sample size used for the test set and the data provenance
- Not Applicable. This document does not describe a new clinical or performance study with a test set. It relies on the substantial equivalence to previously cleared devices (K032268, K043005) and "safety and performance data provided within this Premarket Notification," which typically refers to bench testing, biocompatibility, and information establishing similarity to predicates, rather than a prospective study with human subjects.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not Applicable. As no new human subject test set is described, there's no mention of experts establishing ground truth for such a set.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
- Not Applicable. No test set with expert adjudication is described.
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. The device is a bone graft substitute, not an AI-assisted diagnostic or imaging device. Therefore, MRMC studies and AI assistance metrics are irrelevant.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Not Applicable. The device is not an algorithm or software; it's a physical resorbable calcium salt bone void filler.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- Not Applicable. For a substantial equivalence claim for a bone graft substitute, the "ground truth" relates to the established safety and effectiveness of the predicate devices based on their prior clearances, preclinical data (biocompatibility, resorption characteristics), and potentially historical clinical use data (though not detailed here for a new study).
8. The sample size for the training set
- Not Applicable. As no machine learning or AI algorithm is involved, there is no "training set."
9. How the ground truth for the training set was established
- Not Applicable. No training set is involved.
Summary based on the document:
This 510(k) submission for MBCP™ relies on the principle of substantial equivalence to previously cleared predicate devices (K032268, K043005). The "study" proving the device meets acceptance criteria (in the context of a 510(k)) is the comparison of the new MBCP™ to these predicates, demonstrating that the design, materials, function, and intended use are the same. No new clinical efficacy studies with specific performance metrics against novel acceptance criteria are described in this summary. The safety and effectiveness are "adequately supported by the substantial equivalence information, safety and performance data provided within this Premarket Notification" – this data would typically include bench testing, biocompatibility studies, and a comparison demonstrating sameness to the predicates, rather than a new clinical human study with a test/training set, expert ground truth, or MRMC evaluation.
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