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510(k) Data Aggregation
(56 days)
Triathlon® Hinge Knee System is intended to be implanted with bone cement for the following condition(s):
- There is destruction of the joint surfaces, with or without significant bone deformity.
- The cruciate and/or collateral ligaments do not stabilize the knee joint.
- The ligaments are inadequate and/or the musculature is weak. And/or
- Revision is required of a failed prosthesis where there has been gross instability, with or without bone loss or inadequate soft tissue.
When used with MRH femur and/or MRH tibial baseplate replacement indicated in revision of an existing prosthesis:
- Revision is required of a failed prosthesis where there has been gross instability, with or without bone loss or inadequate soft tissue.
When used with compatible GMRS components:
- Where segmental resection and/or replacement of femur and/or proximal tibia is required
The subject THK components are a line extension of the previously cleared Triathlon® Hinge Knee System (K223528, K230416). The THK System (K223528, K230416) is a tricompartmental knee system consisting of a stemmed femoral component and a stemmed tibial bearing component connected by a set of previously cleared MRH or THK Bushings and an MRH or THK Axle (K994207, K002552, K223528, K230416). A bumper locks this assembly. This assembly provides motion through the MRH or THK Axle/Bushings combination in the flexion/extension plane. The articulation between the bearing surfaces on the underside of a tibial bearing component and a tibial insert provides motion in the rotating plane. A hinge tibial insert is assembled to a Triathlon® Hinge Revision Tibial Baseplate that incorporates a longitudinal bore to accept a previously cleared MRH Tibial Sleeve (K994207, K002552) or Triathlon Tibial Sleeve (K223528, K230416). Optional distal femoral and tibial augments are available to fill bone defects.
The subject Triathlon® Hinge Small Proximal Tibial Bearing Component and Triathlon® End Cap are sterile, single use devices intended for cemented use only and are being added to the previously cleared THK system (K223528, K230416) as an extension. They can be used with previously cleared MRH Knee components (K994207, K002552), GMRS (K023087, K222056), and Triathlon® Knee System components (K172634, K172326, K190991, K143393, K141056, K132624, K070095, K061521, K053514, K052917, K051948, K051146, K040267).
This FDA 510(k) clearance letter is for a mechanical medical device (a knee implant system), not an AI/software as a medical device. Therefore, the request for "acceptance criteria and the study that proves the device meets the acceptance criteria" using metrics relevant to AI/software (like sensitivity, specificity, MRMC studies, ground truth for training/test sets, etc.) is not applicable here.
The document provided details about the substantial equivalence of the "Triathlon® Hinge Knee System" to previously cleared predicate devices. The "study" proving the device meets acceptance criteria for a mechanical implant typically involves non-clinical (benchtop) testing and engineering analyses to demonstrate performance, material compatibility, and safety, rather than clinical trials or AI performance evaluations with ground truth.
Here's how the provided information relates to the typical evaluation of such a device, addressing the closest analogues to your requested points:
Acceptance Criteria and Device Performance for a Mechanical Implant:
For mechanical implants like the Triathlon® Hinge Knee System, "acceptance criteria" are generally tied to the successful completion of various non-clinical (benchtop) tests and analyses. These tests simulate the physical stresses and conditions the implant will experience in the human body. The "study" proving the device meets these criteria is the execution and successful outcome of these non-clinical tests.
No direct table of "acceptance criteria" vs. "reported device performance" in the AI sense is provided in this 510(k) summary. Instead, the summary lists the types of non-clinical tests performed to demonstrate performance and substantial equivalence to predicate devices. The implied acceptance is that the device passed these tests, meaning its performance in these simulated scenarios was deemed acceptable and comparable to existing, legally marketed devices.
Table of Non-Clinical Tests (Analogous to Performance Metrics):
Acceptance Criteria (Test Type) | Reported Device Performance (Implied "Pass") | Notes |
---|---|---|
Triathlon Hinge Bearing Component Varus/Valgus Fatigue | Met performance standards | Tests the component's ability to withstand repeated bending stresses in side-to-side directions, simulating loading during gait. |
Triathlon Hinge Bearing Component Chair Rise Testing | Met performance standards | Simulates stresses experienced during a common activity (standing up from a chair). |
Triathlon Hinge Full Construct Fatigue | Met performance standards | Evaluates the fatigue life of the entire assembled knee system under cyclic loading. |
Wear Test Rationale for New Constructs | Acceptable wear characteristics demonstrated | Rationale provided to show that wear performance is acceptable, likely through comparison to predicate devices or established standards. Direct wear testing is implied by "wear test rationale". |
Analysis of Contact Area/Contact Stress & Constraint Analysis | Acceptable contact mechanics & constraint | Computer modeling and/or benchtop tests to evaluate how the components interact under load, ensuring appropriate stress distribution and constrained movement. |
Range of Motion and Rotational Freedom Analysis (ASTM F1223-20) | Met specified ranges and freedoms | Tested for flexion/extension, internal/external rotation, varus/valgus, and translation (medial/lateral, proximal/distal, anterior/posterior) to ensure physiological movement. |
Total Femur Construct Compatibility & Triathlon Hinge Bushing/Axle Compatibility | Compatible with legacy components | Ensured new components integrate properly with existing cleared femoral and tibial components. |
Triathlon Revision Baseplate-End Cap Locking Strength Analysis | Adequate locking strength | Evaluated the mechanical strength of the connection points. |
Triathlon End Cap Tightening Analysis | Optimal tightening confirmed | Ensured secure fixation of the end cap. |
Triathlon End Cap Load Carrying Capacity Rationale | Acceptable load capacity | Analysis provided to demonstrate the end cap can withstand expected loads. |
Triathlon End Cap Stability Analysis | Stable under normal use | Evaluated the end cap's ability to remain in place and function without loosening. |
MRI Testing (Safety for imaging) - Displacement, Torque, Artifacts, RF Heating | All MRI safety criteria met | Performed to confirm the device is safe for patients undergoing MRI procedures (e.g., no excessive magnetic pull, acceptable image distortion, no dangerous heating). Standards: ASTM F2052-15, ASTM F2213-17, ASTM F2119-07 (reapproved 2013), ASTM F2182-191ae. |
Biocompatibility (ISO 10993-1:2020) | Biocompatible with human tissue | Testing to ensure the materials used in the implant do not cause adverse biological reactions in the body. |
Shelf-life Validation (ISO 11607-1:2019, ISO 11607-2:2019, ASTM F1980-21) | Validated shelf-life | Ensures the sterility and integrity of the packaging system and the device itself are maintained over the specified shelf-life. Methods: ASTM F1886/F1886M-16, ASTM F88/88M-21, ASTM F2096-11(2019). |
Bacterial Endotoxin Testing (ANSI/AAMI ST72:2019) | Endotoxin limit |
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(56 days)
The b-ONE™ MOBIO™ Total Knee System is intended for total knee arthroplasty due to the following conditions: · Painful, disabling joint disease of the knee resulting from: noninflammatory degenerative joint disease (including osteoarthritis, traumatic arthritis, or avascular necrosis), rheumatoid arthritis or post -traumatic arthritis. · Post-traumatic loss of knee joint configuration and function. · Moderate varus, valgus, or flexion deformity in which the ligamentous structures can be returned to adequate function and stability. · Revision of previous unsuccessful knee replacement or other procedure · Fracture of the distal femur and/or proximal tibia that cannot be standard fracture- management techniques. Additional indications for Posterior Stabilized (PS) and Posterior Stabilized Plus (PS+) components: - · Ligamentous instability requiring implant bearing surface geometries with increased constraint. - · Absent or nonfunctioning posterior cruciate ligament. - · Severe anteroposterior instability of the knee joint The b-ONE™ MOBIO™ Total Knee System is intended for implantation with bone cement only. b-ONE™ MOBIO™ Total Knee System components are not intended for use with other knee systems.
The MOBIO Total Knee System is a modular artificial knee replacement system comprised of symmetric cemented femoral components, symmetric cemented tibial tray, symmetric tibial inserts with locking wires, symmetric patellar resurfacing button, and reusable surgical instruments. The therapeutic effect is replacement of the diseased joint with artificial components to restore joint function. This submission is to add a Stemmed Baseplate with modular Stem Extension options. Compatibility of the system components is only claimed with the b-ONE Total Knee System components. There is no allowed interchangeability with systems manufactured by other companies. The b-ONE MOBIO Total Knee System Stemmed Tibial Baseplates are manufactured from forged titanium alloy. The baseplates are offered in 9 sizes with medial lateral dimensional range from 58-85mm and anterior posterior dimensional range from 58-85mm and anterior posterior dimensional range from 38-59mm. The baseplate is intended for cemented fixation. The Stemmed Baseplates mate with stem extensions through a threaded junction. The Tibial Stems are manufactured from forged titanium alloy. The Tibial Stems are offered in 3 diameters (12, 14, and 16mm) with various lengths ranging from 20-120mm. The stems are intended for cemented fixation. All system components are supplied sterile and are single use devices.
The provided text describes a 510(k) premarket notification for a medical device, the MOBIO Total Knee System. This document focuses on demonstrating substantial equivalence to previously cleared predicate devices, rather than establishing acceptance criteria or reporting results from a study proving the device meets those criteria in the way one might expect for an AI algorithm or a diagnostic tool.
The "acceptance criteria" in this context refer to the requirements for demonstrating substantial equivalence for a new or modified medical device. The "study" proving the device meets these criteria is the collection of non-clinical tests and comparisons presented in the 510(k) submission.
Here's a breakdown of the requested information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The provided document doesn't present a table with explicit "acceptance criteria" and "reported device performance" in the quantitative sense typical for a diagnostic or AI device. Instead, the acceptance criteria are implicitly met by demonstrating that the new device's performance, materials, and design are substantially equivalent to those of legally marketed predicate devices.
The "reported device performance" is essentially that the MOBIO Total Knee System is as safe and effective as the predicate devices based on the non-clinical tests performed.
Category | Acceptance Criteria (Implicit from Substantial Equivalence) | Reported Device Performance (Summary from Document) |
---|---|---|
Materials | Materials of construction are substantially equivalent to predicate devices. | Subject device uses forged titanium alloy for baseplates and stems, the same material class as commonly used in predicate knee systems. |
Manufacturing | Manufacturing processes are substantially equivalent to predicate devices. | Standard manufacturing processes for medical implants are used, similar to predicate devices. |
Sizes Offered | Sizes offered are comparable to predicate devices. | Tibial Baseplates offered in 9 sizes (medial-lateral: 58-85mm, anterior-posterior: 38-59mm). Tibial Stems offered in 3 diameters (12, 14, 16mm) with lengths from 20-120mm. These ranges are typical for total knee systems. |
Product Design | Product design (shape, macrostructures) is substantially equivalent to predicate devices. | Design features are comparable to predicate devices, with minor differences not raising new safety/effectiveness questions. This submission focused on adding a Stemmed Baseplate with modular Stem Extension options to an existing cleared system. |
Sterilization | Sterilization methods are substantially equivalent to predicate devices. | All system components are supplied sterile and are single-use devices, consistent with standard practice for surgically implanted devices. |
Mechanical Performance | The device performs mechanically comparably to predicate devices for its intended use, as demonstrated by non-clinical tests. | Non-clinical studies included: Tibial Baseplate Fatigue, Torque Testing, Locking Mechanism Strength, Constraint, Contact Area and Contact Stress, Tibiofemoral Range of Motion. The results are implied to be acceptable as they support substantial equivalence. |
Biocompatibility | The device materials are biocompatible, similar to predicate devices. | Biocompatibility testing was performed. The results are implied to be acceptable as they support substantial equivalence. |
Shelf Life | The device maintains its safety and effectiveness over its stated shelf life. | Shelf Life Studies were performed. The results are implied to be acceptable as they support substantial equivalence. |
Bacterial Endotoxin | The device is free from bacterial endotoxin within acceptable limits. | Bacterial Endotoxin Testing was performed. The results are implied to be acceptable as they support substantial equivalence. |
Safety & Effectiveness | The device is as safe and effective as the legally marketed predicate devices. Differences in design/technology do not raise new safety/effectiveness questions. | "The information provided above supports that the MOBIO Total Knee System Stemmed Baseplate and Stem Extension components are as safe and effective as the predicate devices with the same intended use. Some minor differences in design and technology exist between the subject and predicate devices, however applicable reference devices have been cited to support the conclusion that these differences do not raise any new questions of safety and effectiveness." |
2. Sample Size Used for the Test Set and the Data Provenance
For a medical implant like a total knee system, studies are typically non-clinical (bench testing, mechanical testing) rather than involving patient test data sets in the way an AI algorithm would.
- Sample Size: Not explicitly stated in terms of "test set" size. The "samples" would be the individual components or assemblies tested for fatigue, torque, etc. The document does not specify the number of units tested for each non-clinical study.
- Data Provenance: The studies are non-clinical (bench testing), so there's no patient data involved in this 510(k) summary. These tests would have been conducted in a laboratory setting by the manufacturer or a contract research organization.
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 in the context of this 510(k) submission.
- Ground Truth for Non-Clinical Tests: For mechanical and material tests, the "ground truth" is established by adherence to recognized standards (e.g., ISO, ASTM) and engineering principles, not by expert consensus on clinical images or diagnoses. The "experts" would be the engineers and scientists performing and interpreting these tests.
- The document implies that the internal experts of b-ONE ORTHO, Corp. and potentially external labs were involved in conducting and evaluating these non-clinical tests, following established regulatory and scientific guidelines.
4. Adjudication Method for the Test Set
This question is not applicable. Adjudication methods (like 2+1, 3+1) are used for resolving disagreements among human readers/experts in diagnostic studies, not for non-clinical mechanical testing of medical devices.
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 question is not applicable. This 510(k) is for a total knee replacement system, which is a physical implant, not an AI-assisted diagnostic tool or an imaging modality. There are no "human readers" or "AI assistance" involved in its direct function.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This question is not applicable. The MOBIO Total Knee System is a physical medical device (an implant), not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
As this is a non-clinical 510(k) submission for a physical implant, the "ground truth" for the performance studies refers to:
- Adherence to validated test methods and standards: For example, fatigue testing would be evaluated against established standards for implant longevity.
- Material specifications: Conformance to established material properties for the titanium alloy.
- Design specifications: Proof that the device meets its design intent, often through dimensional verification and mechanical simulation/testing.
- Biocompatibility standards: Compliance with ISO 10993 series for biological evaluation of medical devices.
8. The sample size for the training set
This question is not applicable. As this device is a physical implant and not an AI algorithm, there is no "training set" in the machine learning sense. The "training" for such a device comes from engineering design, material science, and prior knowledge from predicate devices.
9. How the ground truth for the training set was established
This question is not applicable, as there is no "training set" for this type of medical device submission.
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(88 days)
Candidates for total knee replacement include patients with:
- A severely painful and/or severely disabled joint resulting from osteoarthritis, post-● traumatic arthritis, or rheumatoid arthritis
- Moderate valgus, varus, or flexion deformities
- Avascular necrosis of the femoral condyle
- A previous unsuccessful knee replacement, osteotomy, or other knee procedure ●
ATTUNE Revision Knee System implants are designed for use in total knee arthroplasty for patients with:
- Absence or loss of both cruciate ligaments ●
- Moderate varus-valgus or flexion instability that requires a bearing surface with increased ● constraint in the clinical judgment of the surgeon
- Bone loss that requires supplemental fixation in the clinical judgment of the surgeon
The porous-coated metaphyseal sleeves are intended for either cemented or cementless applications.
Any non porous-coated components are intended for cemented use only.
The ATTUNE® Revision Knee System is a total knee replacement prosthesis consisting of various components including ATTUNE REVISION CRS FEMORAL COMPONENTS, ATTUNE REVISION CRS FIXED BEARING INSERTS, ATTUNE REVISION FIXED BEARING TIBIAL BASES, ATTUNE REVISION STEMS, ATTUNE REVISION FEMORAL SLEEVES, ATTUNE REVISION FEMORAL AUGMENTS, ATTUNE REVISION TIBIAL AUGMENTS, and ATTUNE REVISION OFFSET ADAPTOR. These components are made from materials such as cast Co-Cr-Mo alloy, UHMWPE, and Ti-6Al-4V ELI alloy. The system is designed for use in total knee arthroplasty to replace the damaged knee joint articulation.
The provided document is a 510(k) Premarket Notification for a medical device, the ATTUNE® Revision Knee System. This type of submission is for demonstrating substantial equivalence to a legally marketed predicate device, rather than proving the device meets clinical acceptance criteria through a formal clinical study with ground truth and expert consensus. The FDA document explicitly states, “Clinical testing was not necessary to determine substantial equivalence between the ATTUNE Revision Knee System and the predicate devices.”
Therefore, the requested information regarding acceptance criteria, study data, sample sizes for test/training sets, expert qualifications, adjudication methods, MRMC studies, standalone performance, and ground truth types cannot be found in this document.
The document primarily focuses on non-clinical testing to demonstrate substantial equivalence to predicate devices. Below is a summary of the non-clinical performance information provided.
1. A table of acceptance criteria and the reported device performance:
The document describes functional testing performed in compliance with FDA Guidance for Knee Joint Prostheses. While explicit numerical acceptance criteria values are not provided, the general statement below indicates that the measured performance met the necessary thresholds.
Test Category | Reported Device Performance |
---|---|
Functional/Mechanical Testing (e.g., Fatigue, Constraint, Contact Pressure, Interlock Strength) | The results demonstrated that the subject devices are substantially equivalent to the legally marketed predicate devices for anticipated in-vivo loading via various constraint, contact, wear, and fatigue tests. |
Biocompatibility Testing | Not explicitly detailed with performance metrics, but the materials (e.g., Co-Cr-Mo alloy, Ti-6Al-4V ELI alloy, UHMWPE) conform to relevant ASTM standards (e.g., ASTM F75, ASTM F136, ASTM F648, ASTM F620, ASTM F1537, ASTM F799), which are accepted standards for biocompatibility in implantable devices. There is no mention of novel materials requiring new biocompatibility testing data. |
Sterilization & Endotoxin Testing | The proposed devices also meet the requirement of bacterial endotoxin testing as specified in ANSI AAMI ST-72:2011. |
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective):
Not applicable. This document refers to non-clinical, in-vitro mechanical and material testing, not human-subject testing involving datasets.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
Not applicable. No ground truth based on expert review was established in this submission.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
Not applicable.
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. No MRMC comparative effectiveness study was performed or required for this device.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
Not applicable. This is a knee implant, not an AI/algorithm device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
Not applicable. The "ground truth" in this context is adherence to established engineering standards (ASTM F75, F136, F648, F620, F1537, F799, ANSI AAMI ST-72:2011) and FDA Guidance for mechanical performance testing for knee prostheses.
8. The sample size for the training set:
Not applicable. No training set for an algorithm was used.
9. How the ground truth for the training set was established:
Not applicable.
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(96 days)
General Total Knee Arthroplasty (TKR) Indications:
- Painful, disabling joint disease of the knee resulting from: noninflammatory degenerative joint disease (including osteoarthritis, traumatic arthritis, or avascular necrosis), rheumatoid arthritis or post-traumatic arthritis.
- Post-traumatic loss of knee joint configuration and function.
- Moderate varus, valgus, or flexion deformity in which the ligamentous structures can be returned to adequate function and stability.
- Revision of previous unsuccessful knee replacement or other procedure.
- Fracture of the distal femur and/or proximal tibia that cannot be stabilized by standard fracture -management techniques.
The Triathlon® Tritanium® Tibial Baseplate and Tritaium® Metal-Backed Patella components are indicated for both uncemented and cemented use.
The Triathion® Total Knee System beaded and beaded with Peri-Apatite components are intended for uncemented use only.
The Triathlon® All Polyethylene tibial components are indicated for cemented use only.
Additional Indications for Posterior Stabilized (PS) and Total Stabilizer (TS) Components:
- Ligamentous instability requiring implant bearing surface geometries with increased constraint.
- Absent or non-functioning posterior cruciate ligament.
- Severe anteroposterior instability of the knee joint.
Additional Indications for Total Stabilizer (TS) Components:
- Severe instability of the knee secondary to compromised collateral ligament integrity or function.
Indications for Bone Augments:
- Painful, disabling joint disease of the knee secondary to: degenerative arthritis, rheumatoid arthritis, or post-traumatic arthritis, complicated by the presence of bone loss.
- Salvage of previous unsuccessful total knee replacement or other surgical procedure, accompanied by bone loss.
The Triathlon® Tritanium® Metal-Backed Patella is an extension of the Triathlon® Total Knee System product line for use in primary and revision Total Knee Arthroplasty. It is a sterile, single-use, non-modular metal-backed patella that is manufactured from UHMWPE (ASTM F648) and commercially pure titanium (ASTM F1580). The device is offered in symmetric and asymmetric designs that are available in multiple sizes. The metalbacking features a porous-coated posterior surface and three porous-coated pegs to provide cemented or cementless fixation to bone.
This document, a 510(k) Summary for the Triathlon® Tritanium® Metal-Backed Patella, focuses on demonstrating substantial equivalence to previously cleared devices rather than presenting a study of a device meeting specific acceptance criteria through performance data. Therefore, many of the requested elements for describing an acceptance criteria study are not present in this submission.
Here's a breakdown based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
This document does not contain a table of acceptance criteria with corresponding device performance metrics in the typical sense of a clinical or analytical performance study. Instead, it lists non-clinical laboratory tests performed to demonstrate substantial equivalence to predicate devices. The "reported device performance" in this context is the successful completion of these tests, implying that the new device performs comparably to the predicates.
Acceptance Criteria (Implied by Test Type) | Reported Device Performance |
---|---|
Material Properties: | |
Elemental Composition (ASTM E1941, E1447, E1409) | Tested and found comparable to predicates |
Metallurgical & Morphological Properties (ASTM E112, F1854) | Tested and found comparable to predicates |
Mechanical Properties (ASTM F1147, F1044, F1160, E8) | Tested and found comparable to predicates |
Plastic Deformation of Porosity (ASTM F1854) | Tested and found comparable to predicates |
Mechanical Performance: | |
Static Tensile Bond Strength of UHMWPE/Metal Interface | Tested and found comparable to predicates |
Static Peg Shear Strength | Tested and found comparable to predicates |
Patello-Femoral Contact Stress/Contact Area | Tested and found comparable to predicates |
Malaligned Endurance Testing | Tested and found comparable to predicates |
Patellar Subluxation Testing | Tested and found comparable to predicates |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: Not explicitly stated for each test. For non-clinical laboratory testing, the sample size typically refers to the number of test articles (patellar components) subjected to each specific test. This tends to be much smaller than clinical study sample sizes and is dependent on the specific ASTM standard or internal protocol used.
- Data Provenance: The tests are non-clinical laboratory tests, likely conducted by the manufacturer (Stryker Orthopaedics) or a contract laboratory. The "country of origin of the data" would typically be the location of the testing facility, which is not specified but presumed to be a regulated environment. The data is retrospective in the sense that these are engineering and material characterization tests performed on manufactured devices.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This information is not applicable as this submission is for a medical device and relies on engineering and material testing standards (ASTM) to demonstrate substantial equivalence, not on expert ground truth for an AI or diagnostic device.
4. Adjudication Method for the Test Set
This is not applicable. The "test set" here refers to physical components undergoing laboratory testing, not, for example, medical images requiring expert adjudication.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study was not done. This type of study is used for diagnostic or AI-assisted devices to assess human reader performance. This submission is for a physical orthopedic implant.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
No, a standalone algorithm performance study was not done. This concept applies to AI/software as a medical device, which this orthopedic implant is not.
7. The Type of Ground Truth Used
The "ground truth" for this submission are the established engineering and material specifications, as well as the performance characteristics of the predicate devices. The new device is tested against these benchmarks (often defined by ASTM standards) to show that its properties are within acceptable ranges and comparable to the predicates.
8. The Sample Size for the Training Set
This is not applicable. There is no "training set" in the context of an orthopedic implant submission based on substantial equivalence through non-clinical testing. This term is relevant for machine learning algorithms.
9. How the Ground Truth for the Training Set Was Established
This is not applicable for the same reasons as point 8.
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