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510(k) Data Aggregation
(198 days)
COPAL® exchange G knee (polymethylmethacrylate/gentamicin) is indicated for temporary use (maximum of 180 days) as a total knee replacement (TKR) in skeletally mature patients undergoing a two-stage procedure due to a septic process. COPAL® exchange G knee is applied on the femoral condyles and on the tibial plate following removal of the existing implant and radical debridement. The device is intended for use in conjunction with systemic antimicrobial antibiotic therapy (standard treatment approach to an infection).
COPAL® exchange G knee is not intended for use for more than 180 days, at which time it must be explanted, and a permanent device implanted, or another appropriate treatment performed (e.g., resection arthroplasty, fusion, etc.). COPAL® exchange G knee is only indicated for patientswho will consistently use traditional mobility assist devices e.g. crutches, walkers, canes) throughout the implantation period.
COPAL® exchange G hip (polymethylmethacrylate / gentamicin) is indicated for temporary use (maximum of 180 days) as a total hip replacement (THR) in skeletally mature patients undergoing a two-stage procedure due to a septic process. The device is inserted into the femoral medullary canal and acetabular cavity following removal of the existing implant and radical debridement. The device is assigned to be used in conjunction with systemic antimicrobial antibiotic therapy (standard treatment approach to an infection). COPAL® exchange G hip is not intended for use for more than 180 days, at which time it must be explanted, and a permanent device implanted, or another appropriate treatment performed (e.g., resection arthroplasty, fusion, perm etc.). COPAL®exchange G hip is only indicated for patients who will consistently use traditional mobility assist devices (e.g. crutches, walkers, canes) throughout the implantation period.
The COPAL® exchange G Hip and Knee Spacers are combination products that provide patients, undergoing a two-stage revision procedure for an infected total joint, a temporary implant to 1) allow for partial weight bearing and 2) provide an approximate natural range of motion. The devices also maintain a patient's soft tissue and joint space, preventing further complications such as muscular contraction. The gentamicin protects the device from bacterial colonization.
The COPAL® exchange G Hip and Knee Spacers are placed into the joint to maintain normal joint space and alignment. They provide patient comfort and limited mobility while the infection is being treated. The COPAL® exchange G Hip and Knee Spacers are made with bone cement that are loaded with gentamicin antibiotics. The COPAL® exchange G Hip and Knee Spacers are temporary joint prostheses designed to temporarily replace an infected implant during a total hip or knee arthroplasty and provide the patient with limited mobility and predictable, consistent local antibiotic release
COPAL® exchange G Hip Spacer is a single use device that mimics a hemi-hip prosthesis and is available in 8 sizes and usable for both left and right hips.
The COPAL® exchange G Hip Spacers are combination products made of fully formed polymethylmethacrylate (radiopaque PMMA with gentamicin). The COPAL® exchange G Hip Spacers contain an inner stainless steel (AISI 316L stainless steel) reinforcing structure. The mass used in the filling of the molds (the PMMA unformed resin) is prepared from a powder component and a liquid component. The liquid component consists of methyl methacrylate, N, N-dimethyl-p-toluidine, hydroquinone. The powder component consists of polymethymethacrylate, calcium carbonite, benzoyl peroxide, and gentamicin sulphate. The raw materials and a summary of the manufacturing process are found below.
COPAL® exchange G Knee Spacer is a single use device that is comprised of a tibia and femur component and is available in 3 sizes to form one knee spacer that is usable for left and right knee.
The provided text describes a 510(k) premarket notification for Heraeus Medical GmbH's COPAL® exchange G Hip and Knee Spacers. The document focuses on demonstrating substantial equivalence to predicate devices, rather than establishing de novo clinical performance with specific acceptance criteria that an AI/ML device would typically face.
Due to the nature of this submission (510(k) for a physical medical device, not an AI/ML algorithm), the information required for filling out the requested table regarding acceptance criteria and performance of an "AI/ML device" is largely not applicable or not present in the document. The performance testing section refers to physical and biological tests, not AI model metrics.
However, I will extract what is available and clearly state what information is missing based on your request.
Here's an attempt to address your request based solely on the provided text, while making the critical distinction that this document does not pertain to an AI/ML device:
Acceptance Criteria and Study for COPAL® exchange G Hip and Knee Spacers (as described in K191016)
Note: The provided document describes the 510(k) clearance for physical medical devices (hip and knee spacers) and not an Artificial Intelligence/Machine Learning (AI/ML) device. Therefore, the typical acceptance criteria and study design elements requested for an AI/ML device (e.g., sensitivity, specificity, expert ground truth, MRMC studies, training/test sets) are not relevant or present in this submission. The "acceptance criteria" for this device are demonstrated through equivalence to predicate devices via various physical, chemical, and biological performance testing, not through AI/ML performance metrics.
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category (Reinterpreted for a physical device) | Specific Criteria (from text) | Reported Device Performance (from text) |
---|---|---|
Biocompatibility | Adherence to ISO 10993-1, -3, -5, -6, -10, -11, -12 for various tests (cytotoxicity, irritation, hypersensitivity, acute/subchronic systemic toxicity, mutation assays, femoral bone implantation). | - In vitro cytotoxicity: No leachable substances dissolved in cytotoxic amounts. |
- Irritation: No signs of irritation; classified as not irritant.
- Delayed-type hypersensitivity: No reactions identified as sensitization.
- Acute systemic toxicity: No acute systemic toxic characteristics.
- Reverse mutation assay: Non-mutagenic.
- In vitro mammalian cell gene mutation assay: Non-mutagenic.
- Femoral bone implantation/subchronic systemic toxicity: No inflammatory or degenerative findings at implantation sites.
- Summary: COPAL® exchange G spacers are biocompatible according to ISO10993-2016. |
| Sterilization Validation | Sterility Assurance Level (SAL) of 10-6 according to ISO 11135 and AAMI TIR 28. | Chosen sterilization process (ethylene oxide gassing) is valid; sterile units achieved with defined bioburden and SAL of 10-6. |
| Shelf Life | Maintain sterility (DIN EN ISO 11737. Part 2), compressive strength (ISO 7206-6 and ISO 14879-1), gentamicin content, and gentamicin impurities over 36 months at 25 ± 2 °C. | All hip/knee spacers sterile throughout 36-month storage. Compressive strength within specified range. Gentamicin content and impurities remained within specified range.
Summary: Stable at 25 ± 2 °C and 50% humidity for 36 months. |
| Sterile Barrier Integrity | Adherence to ISO 11607-1 and ISO 11607-2, including maintenance over 5 years of transport and shelf life. | Integrity of the system shown; maintenance of sterile barrier system demonstrated over 5 years. |
| Mechanical Performance | Compressive strength (ISO 14879-1, ISO 7206-4, ISO 7206-6), cyclic fatigue (ISO 14879-1, ISO 14242-1:2012), abrasion (ISO 14243-1:2009, ISO 14242-1:2012) demonstrating equivalence to predicate devices. | - Compressive strength: Equivalent to predicate devices. - Cyclic fatigue: Equivalent to predicate devices.
- Abrasion: Equivalent to predicate devices. |
2. Sample Size Used for the Test Set and Data Provenance
Due to the nature of the device (physical implant, not software/AI):
- Sample Size for Test Set: This concept doesn't directly apply in the "AI/ML" sense of a data test set. The document refers to "tests performed" and "results obtained" for various physical and biological properties. Specific quantitative sample sizes for each test (e.g., number of hip spacers tested for compressive strength) are not provided in this summary.
- Data Provenance: Not applicable in the context of an AI/ML algorithm (e.g., country of origin of patient data). The testing data is generated in a lab setting through physical and chemical tests on the manufactured devices. The document implies these tests were conducted by the manufacturer (Heraeus Medical GmbH, Germany).
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Experts
- This is not applicable for this type of device submission. Ground truth, in the AI/ML context, refers to expert labeling of data (e.g., images). For this physical device, "ground truth" is established by adherence to recognized international standards and laboratory testing protocols performed by qualified professionals in those fields (e.g., materials science, microbiology, mechanical engineering). The specific number or qualifications of these testing personnel are not detailed in the summary.
4. Adjudication Method for the Test Set
- This is not applicable for this type of device submission. Adjudication, in the AI/ML context, is typically used for resolving disagreements among multiple human annotators during ground truth establishment. For a physical device, passing/failing criteria are set by the established standards and internal quality control.
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 as the device is not an AI/ML algorithm intended to assist human readers.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
- This is not applicable as the device is not an AI/ML algorithm.
7. The Type of Ground Truth Used
- The "ground truth" for these physical devices is established by compliance with recognized international standards (e.g., ISO, ASTM) for material properties (e.g., mechanical strength, chemical composition), biological interactions (biocompatibility), and manufacturing processes (sterilization, shelf life). The "outcome data" is whether the device meets these pre-defined physical and biological performance specifications and demonstrates equivalence to the predicate device.
8. The Sample Size for the Training Set
- This is not applicable as the device is not an AI/ML algorithm. There is no concept of a "training set" in this context. The product is manufactured based on design specifications and then tested for performance.
9. How the Ground Truth for the Training Set was Established
- This is not applicable as the device is not an AI/ML algorithm.
In conclusion, the provided FDA 510(k) submission is for a physical medical device (hip and knee spacers) and not for an AI/ML-based device. Therefore, the requested information regarding AI/ML-specific acceptance criteria, study methodologies (e.g., human-in-the-loop, standalone, MRMC), and data sets (training, test, ground truth establishment) is largely irrelevant to this document. The document primarily focuses on demonstrating substantial equivalence through various physical, chemical, and biological performances tests against established standards and predicate devices.
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(126 days)
The Remedy® Shoulder Spacer, which consists of a modular head and stem, is indicated for temporary use (maximum 180 days) as an adjunct to total or hemi-shoulder replacement in skeletally mature patients undergoing a two-stage procedure due to a septic process and where gentamicin is the most appropriate antibiotic based on the susceptibility pattern of the infecting micro-organisms.
The head and stem components are inserted into the glenoidal cavity and humeral medullary canal, respectively, following removal of the existing prosthetic components and radical debridement. The device is intended for use in conjunction with systemic antimicrobial antibiotic therapy (standard treatment approach to an infection).
The Remedy® Shoulder Spacer is not intended for use for more than 180 days, at which time it must be explanted and a permanent device implanted or another appropriate treatment performed (e.g. resection arthroplasty, fusion etc.).
The Remedy® Shoulder Spacer is a sterile, single-use device intended for temporary use (maximum 180 days) as shoulder replacement.
The Remedy® Shoulder Spacer is composed of two components (a head and a stem) that are intended to be used together to form a temporary shoulder spacer; the components are available in a range of sizes.
The device is made of fully formed polymethylmethacrylate (PMMA), which is radioopaque and contains gentamicin. The stem component has also an inner stainless steel reinforcing structure.
The Remedy® Shoulder Spacer provides a functional-mechanical mode of action; it provides patients a temporary implant allowing for a natural range of motion and partial weight-bearing during treatment. It is designed to preserve soft tissue to prevent further complications, such as muscular contraction, and to facilitate the subsequent joint replacement procedure.
This document appears to be a 510(k) Summary for a medical device called the "Remedy® Shoulder Spacer." It focuses on demonstrating substantial equivalence to a predicate device rather than presenting a study designed to meet specific acceptance criteria in the way one would for an AI/ML powered device.
Therefore, many of the requested categories for AI/ML device studies (like sample size for test set, number of experts, adjudication method, MRMC study, standalone performance, training set details) are not applicable to this document as it describes a physical orthopedic implant, not a software algorithm.
Below is an attempt to map the available information to the closest relevant categories, with explanations for why certain sections are not applicable.
1. Table of Acceptance Criteria and Reported Device Performance
As this is not an AI/ML device, the concept of "acceptance criteria" for diagnostic performance metrics (e.g., sensitivity, specificity, AUC) is not present. Instead, the document discusses performance testing designed to demonstrate safe and effective mechanical function and material properties, and equivalence to a predicate device. The "acceptance criteria" would be compliance with relevant standards and demonstration of properties comparable to the predicate.
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Sterilization: Compliance with international standards. | Sterilization cycles validated following international standards. |
Shelf Life: Established through stability testing. | Established through stability studies. Shelf life is 5 years, same as predicate. |
Biocompatibility: Safe, biocompatible materials for intended use, compliant with ISO 10993 and FDA Draft Guidance. | Biocompatibility evaluation performed, showing device materials are safe, biocompatible, and suitable for intended use, taking into account ISO 10993 and FDA Draft Guidance. |
Mechanical Performance: Static and fatigue performance acceptable and comparable to predicate. | Performance testing included evaluation of static and fatigue performances. (The document states "The performance data demonstrate that the new devices are substantially equivalent to the predicate device Tecres' Interspace Shoulder" implies these tests met the necessary benchmarks for equivalence). |
Surface Roughness: Acceptable and comparable to predicate. | Performance testing included evaluation of surface roughness. (Implied acceptability and equivalence to predicate). Reference devices for surface roughness: Tecres InterSpace Knee (K062273 and K062274) and OsteoRemedies Knee Modular Spacer (K112470). |
Disassembling: Acceptable performance. | Performance testing included evaluation of disassembling. (Implied acceptability and equivalence to predicate). |
Antibiotic Elution: Gentamicin elution effective and comparable to predicate. | Performance testing included antibiotic (gentamicin) elution testing. (Implied acceptability and equivalence to predicate). The device is made of PMMA containing gentamicin, and the predicate also contains gentamicin. The indications for use specify "where gentamicin is the most appropriate antibiotic." |
Material Composition: Same as predicate. | Main Components: Polymethylmethacrylate (PMMA), Methylmethacrylate (MMA), Barium Sulphate (Same as predicate). |
Other Components: Benzoyl peroxide, N,N-Dimethyl-p-toluidine, Hydroquinone (Same as predicate). | |
Antibiotics: Gentamicin Sulphate (Same as predicate). | |
Inner core: Stainless Steel (AISI 316 ESR) (Same as predicate). | |
Design (Shape): Different but functionally equivalent. | Design is Head + Stem (separated) for Remedy® vs. Head + Stem (monoblock) for predicate. This is a "Different" characteristic, but the overall performance data is presented to show substantial equivalence. |
Modularity: Different from predicate. | Remedy® has 3 heads, 3 stems, offset adjustment vs. None for predicate. This is a "Different" characteristic, but the overall performance data is presented to show substantial equivalence, suggesting the modularity does not negatively impact safety or efficacy. |
Sizes: Different but comparable range. | Head Size: Ø: 40 – 45 – 50 mm (Remedy®) vs. Ø: 41 – 46 mm (Predicate). |
Stem Size: L: 101 mm Ø: 7 mm, L: 116 mm Ø: 10.5 mm, L: 131 mm Ø: 14 mm (Remedy®) vs. L: 99 mm Ø: 7 mm, L: 125 mm Ø: 11 mm (Predicate). While "Different," the sizes are intended to cover most shoulder prosthesis configurations currently available, indicating a functional expansion rather than a deviation in core performance. | |
Stem-neck angle: Same as predicate. | 130° (Same as predicate). |
X-ray visibility: Yes (Same as predicate). | Yes (Same as predicate). |
Single-use device: Yes (Same as predicate). | Yes (Same as predicate). |
Provided Sterile: Yes (Same as predicate). | Yes (Same as predicate). |
Sterilization Method: Ethylene Oxide (Same as predicate). | Ethylene Oxide (Same as predicate). |
Sterility Assurance Level (SAL): 10-6 (Same as predicate). | 10-6 (Same as predicate). |
2. Sample size used for the test set and the data provenance
This is not applicable for a physical device 510(k) submission in the context of diagnostic "test sets." The performance data is based on laboratory testing of the device itself and its components, according to established engineering and material science protocols. There is no biological "data" in the sense of patient images or clinical outcomes that would have "provenance."
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This is not applicable. "Ground truth" in this context refers to a standard of truth for diagnostic or clinical outcome data, which is not evaluated here. The "truth" for device performance is established through physical and chemical testing against engineering standards and comparison to a predicate device.
4. Adjudication method for the test set
This is not applicable. There is no clinical "test set" requiring adjudication by experts.
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 as this is not an AI/ML device or a diagnostic device involving "human readers."
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable as this is not an AI/ML device.
7. The type of ground truth used
This is not applicable in the AI/ML sense. The "ground truth" for the device's acceptable performance is defined by:
- Compliance with recognized standards: e.g., ISO for biocompatibility, sterilization standards.
- Engineering and material science principles: for mechanical strength, fatigue, material composition.
- Comparative data to a legally marketed predicate device: demonstrating that the new device is "substantially equivalent" in terms of safety and effectiveness.
8. The sample size for the training set
This is not applicable as this is not an AI/ML device. There is no concept of a "training set" for a physical orthopedic implant.
9. How the ground truth for the training set was established
This is not applicable as this is not an AI/ML device.
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(494 days)
Spacer-K is indicated for temporary use (maximum of 180 days) as a total knee replacement (TKR) in skeletally mature patients undergoing a two-stage procedure due to a septic process.
Spacer-K is applied on the femoral condyles and on the tibial plate following removal of the existing implant and radical debridement. The device is intended for use in conjunction with systemic antimicrobial antibiotic therapy (standard treatment approach to an infection).
Spacer-K is not intended for use for more than 180 days, at which time it must be explanted and permanent device implanted or another appropriate treatment performed (e.g., resection arthroplasty, fusion, etc.). Because of the inherent mechanical limitations of the device material (gentamicin/polymethylmethacrylate), Spacer-K is only indicated for patients who will consistently use traditional mobility assist devices (e.g. crutches, walkers, canes) throughout the implantation period.
Spacer-G is indicated for temporary use (maximum of 180 days) as a total hip replacement (THR) in skeletally mature patients undergoing a two-stage procedure due to a septic process.
The device is inserted into the femoral medullary canal and acetabular cavity following removal of the existing implant and radical debridement. The device is intended for use in conjunction with systemic antimicrobial antibiotic therapy (standard treatment approach to an infection).
Spacer-G is not intended for use for more than 180 days, at which time it must be explanted and a permanent device implanted or another appropriate treatment performed (e.g., resection arthroplasty, fusion, etc.).
Spacers are temporary joint prostheses. Spacer-G is a single piece device that mimics a hemi-hip prosthesis, and is available in six sizes. Spacer-K includes a femoral and tibial component, and is available in three sizes. Spacer-G and Spacer-K are made of fully formed polymethylmethacrylate (radiopaque PMMA with gentamicin). Spacer-G contains an inner stainless steel (AISI 316L stainless steel) reinforcing structure. The mass used in the filling of the molds (the PMMA unformed resin) is prepared from a powder component and a liquid component. The liquid component consists of methylmethacrylate, N,N-dimethyl-p-toluidine, hydroquinone; the powder component consists of polymethymethacrylate, barium sulphate, benzovl peroxide, and gentamicin sulphate.
The Spacer devices provide patients, undergoing a two-stage revision procedure for an infected total joint, a temporary implant to 1) allow for partial weight bearing and 2) provide a natural range of motion. The devices also maintain a patient's soft tissue and joint space, preventing further complications such as muscular contraction. The gentamicin protects the device from bacterial colonization.
Here's a breakdown of the acceptance criteria and study information for the Tecres Spacer-G and Spacer-K, based on the provided documents:
Acceptance Criteria and Device Performance
The provided 510(k) summary (K101356) does not explicitly state specific quantitative acceptance criteria or detailed performance data in a table format. Instead, it relies on substantiating that the modified devices (Spacer-G and Spacer-K) are substantially equivalent to their previously cleared versions (K062274 for Spacer-K and K062273 for Spacer-G).
The core acceptance criterion implicitly stated is:
- The modified Spacer devices must perform equivalently to their previously cleared versions, ensuring continued safety and effectiveness for their intended temporary use.
The reported device performance is described as:
- "Performance testing was conducted to verify that implant performance continues to meet the production specifications and be adequate for in vivo applications under the temporary conditions of use."
- "Mechanical properties, gentamicin release and stability data were evaluated and found to support the substantial equivalence of the devices."
Without quantitative metrics provided in these documents, a table cannot be fully populated. However, we can infer the categories of assessment:
Acceptance Criteria Category | Reported Device Performance (Qualitative) |
---|---|
Mechanical Properties | Evaluated and found to support substantial equivalence to previously cleared devices. |
Gentamicin Release | Evaluated and found to support substantial equivalence to previously cleared devices (for antibacterial function). |
Stability | Evaluated and found to support substantial equivalence to previously cleared devices. |
Production Specifications | Implant performance continues to meet production specifications. |
In Vivo Adequacy | Adequate for in vivo applications under temporary conditions of use. |
Study Information
The 510(k) summary for K101356 describes an evaluation for "substantial equivalence" rather than a de novo clinical study with patients. The study primarily involves performance testing to compare a modified device (minor material change) to an established, previously cleared device.
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Sample size used for the test set and the data provenance:
- The document does not specify the sample size for any test set in terms of clinical data or patient cohorts. The performance testing appears to be conducted on the devices themselves (e.g., in vitro mechanical testing, elution studies).
- Data provenance: Not explicitly stated as retrospective or prospective clinical data. Given the nature of a 510(k) for a minor material change to a previously cleared device, the testing would likely be bench testing and possibly some in vitro or ex vivo studies. No specific country of origin for clinical data is mentioned as such data doesn't appear to be the primary basis for this particular submission.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable in the context of this 510(k) submission. The evaluation is based on engineering and material science performance testing, not on interpretation of patient data by medical experts. "Ground truth" here refers to established material properties and performance benchmarks.
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Adjudication method for the test set:
- Not applicable as there is no mention of a human expert review or adjudication process for a test set of clinical cases. The evaluation is against engineering specifications and pre-established performance of the predicate device.
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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:
- Not applicable. This device is a temporary orthopedic implant, not an AI-powered diagnostic or assistive tool.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device is a physical medical device.
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The type of ground truth used:
- Engineering specifications and performance characteristics of the previously cleared predicate devices (K062274 and K062273). The "ground truth" for the modified device's performance is that it matches or exceeds the established performance of its predecessors, as demonstrated through mechanical, gentamicin release, and stability testing.
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The sample size for the training set:
- Not applicable. This is not an AI/machine learning study, so there is no concept of a "training set."
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How the ground truth for the training set was established:
- Not applicable.
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