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510(k) Data Aggregation

    K Number
    K170802
    Date Cleared
    2017-09-28

    (195 days)

    Product Code
    Regulation Number
    888.3027
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K090460, K090435, K121876

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

    The TRAUMACEM™ V+ Injectable Bone Cement is indicated for augmentation of the TFN-ADVANCED® Proximal Femoral Nailing System through cannulated implants and instruments for patients with poor bone quality (e.g., osteoporosis).

    Device Description

    TRAUMACEM™ V+ Injectable Bone Cement consists of sterile packed powder and liquid components to create radiopaque TRAUMACEM™ V+ Injectable Bone Cement. The powder component is pre-packed in the mixer. The liquid component is stored in a glass ampoule. A transfer lid for the mixing and transfer of the bone cement in the application system is also contained in the kit. Mixing the two sterile components produces the injectable bone cement.

    AI/ML Overview

    The provided text describes the regulatory filing for a medical device, TRAUMACEM™ V+ Injectable Bone Cement, and discusses its substantial equivalence to predicate devices, supported by various performance tests and clinical evidence. However, this document does not describe a study that proves a device meets acceptance criteria related to an AI/ML algorithm or a comparative effectiveness study involving human readers with and without AI assistance.

    The information provided pertains to the premarket notification (510(k)) process for a physical medical device (bone cement). The "acceptance criteria" discussed are in the context of demonstrating substantial equivalence to a legally marketed predicate device, primarily through physical, chemical, and biomechanical testing, as well as review of existing clinical data.

    Therefore, many of the requested points related to AI/ML device validation (e.g., sample size for test sets, data provenance, expert ground truth establishment, MRMC studies, standalone AI performance) are not applicable to the content of this document.

    Here's a breakdown based on the provided text, highlighting what is present and what is not:


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

    The document doesn't present a formal table of acceptance criteria and corresponding performance for the bone cement in the way one would for an AI/ML diagnostic device with specific metrics like sensitivity, specificity, or AUC. Instead, it states that the device was compared to predicate and reference devices and "meets the requirements of ASTM F451-08/ISO 5833:2002 (apart from setting and dough time)." It also lists various performance tests conducted:

    Acceptance Criterion (Implicit)Reported Device Performance (Implied, from tests conducted)
    Material Standards ComplianceMeets the requirements of ASTM F451-08/ISO 5833:2002 (apart from setting and dough time).
    Biomechanical PerformanceBiomechanical evaluation of cut-out resistance conducted. (Specific metrics not provided, but implies satisfactory performance given 510(k) clearance).
    Cadaveric PerformanceCadaveric evaluation of cut-out resistance conducted. (Specific metrics not provided).
    Delivery/Handling (via cannulated implants)Cannulated implant removal evaluation conducted. TRAUMACEM™ V+ Injectable Bone Cement was designed to have increased radiopacity and working time to facilitate delivery through cannulated implants and instruments.
    RadiopacityRadiopacity comparison conducted. TRAUMACEM™ V+ Injectable Bone Cement was designed to have increased radiopacity.
    BiocompatibilityCytotoxicity, Irritation, Sensitization, Material mediated pyrogenicity, Genotoxicity (in vitro and in vivo), Implantation, Chemical characterization conducted. (The conclusion is that benefits outweigh risks, implying satisfactory biocompatibility).
    Clinical Outcomes (for its intended use)One prospective, multicenter, randomized, postmarket study conducted outside the US comparing outcomes in patients with unstable trochanteric fractures treated with or without Traumacem V+ Augmentation. Two peer-reviewed publications summarizing short-term and long-term outcomes of patients with trochanteric fractures treated with cephalomedullary nail augmentation with PMMA bone cements.

    Reported Outcomes: No cases of cut-out were observed. Potential risks (e.g., cement leakage) had a low rate of occurrence. Data correlated well with real-world market experience outside the US. Indications, method of use, and patient populations confirmed to align with intended use. |

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Test Set (for clinical evidence):
      • One prospective, multicenter, randomized, postmarket study conducted. The sample size for this specific study is not provided in the document.
      • Two summaries of peer-reviewed publications. The sample sizes for these publications are not provided.
      • Data Provenance: Studies were conducted outside the US. The randomized study described was prospective and postmarket. The publications summarized outcomes from patients treated with PMMA bone cements (presumably retrospective or prospective depending on the original study designs, but not specified here). Real-world market experience outside the United States also mentioned.

    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 is not applicable as the studies described are clinical outcome studies for a bone cement, not diagnostic studies where experts establish ground truth from images. The "ground truth" here would be clinical outcomes (e.g., presence/absence of cut-out, leakage rates) observed by clinicians.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. This is relevant for diagnostic studies with image interpretations, not for a bone cement clinical outcome study. Clinical outcomes would be determined by treating physicians and follow-up assessments.

    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

    • No, an MRMC comparative effectiveness study was not done. This document describes a physical bone cement, not an AI/ML diagnostic device that assists human readers.

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

    • No, this is not applicable. The device is a physical bone cement, not an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • For the clinical evidence presented, the "ground truth" was outcomes data (e.g., presence/absence of cut-out, cement leakage rates) gathered from clinical studies and real-world market experience.

    8. The sample size for the training set

    • Not applicable. This isn't an AI/ML device that uses a training set.

    9. How the ground truth for the training set was established

    • Not applicable. This isn't an AI/ML device that uses a training set.

    In summary: The provided document is a regulatory clearance letter and summary for a physical medical device (bone cement). It demonstrates the device's equivalence to existing products through a combination of physical, chemical, biomechanical, and biocompatibility testing, along with references to existing clinical studies and real-world data. It does not provide information relevant to the validation of an AI/ML-driven diagnostic or treatment planning system.

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    K Number
    K161114
    Device Name
    HIGH V+
    Manufacturer
    Date Cleared
    2017-04-12

    (357 days)

    Product Code
    Regulation Number
    888.3027
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K090435, K032945

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

    The HIGH V+ is used for the fixation of pathological fractures of the vertebroplasty or kyphoplasty procedures. Painful vertebral compression fractures of the vertebral body may result from osteoporosis, benign lessons (hemangiona), or malignant lesions (metastatic cancers, myeloma).

    Device Description

    HIGH V+ is a self-hardening and ready to use Poly Methylmethacrylatebone cement with 36.4% of radiopaque agentsfor the treatment of painfulvertebral fractures based on the predicate devices Spineplex. Vertecem. It can be injected directly into the fractured vertebral body by either Vertebroplasty or Kylphoplasty procedures to relieve pain. HIGH V+ allows an excellent consolidation of the vertebral body and an effective and rapid pain relief. The HIGH V+ cement is made of two sterile components: the polymer in powder and the liquid monomer. These two components are in a double sterile packaging. Each unit contains a sterile ampoule of liquid within a blister pack and a powder within a double peelable pouch, the whole being packaged in a box.

    AI/ML Overview

    This document is a 510(k) summary for the HIGH V+ bone cement, which is a medical device for fixing vertebral fractures. The summary focuses on demonstrating the substantial equivalence of HIGH V+ to predicate devices (Vertecem and Spineplex) rather than proving performance against specific acceptance criteria through a clinical study.

    Therefore, many of the requested elements for describing "acceptance criteria and the study that proves the device meets the acceptance criteria" are not directly applicable or available in this type of submission. This 510(k) submission primarily relies on non-clinical (bench) testing to show equivalence in material properties and functional characteristics.

    Here's the breakdown of the information that can be extracted from the document, and where the requested details are not present:


    1. Table of acceptance criteria and the reported device performance

    The document does not explicitly present "acceptance criteria" in the traditional sense of a clinical trial's primary endpoints. Instead, it presents various physical and chemical characteristics of the HIGH V+ and compares them to predicate devices and the ISO 5833 standard. The "acceptance" is implied by meeting or being comparable to these established benchmarks for bone cement.

    Characteristic / TestAcceptance Criteria (Implied by Predicate/Standard)Reported Device Performance (HIGH V+)
    Chemical Composition (Powder)
    PolymethymethacrylateComparable to Vertecem (43.4% ± 1%) & Spineplex (11.5%)63.1% ± 1%
    Benzoyl peroxideComparable to Vertecem (0.5% ± 0.1%) & Spineplex (1.5%)0.5% ± 0.1%
    Barium sulfateComparable to Vertecem (30% +2% -3%) & Spineplex (30%)27.3% +2.1% - 1.9%
    HydroxyapatiteComparable to Vertecem (10% ± 1%)9.1% +1.9% / -2.1%
    Chemical Composition (Liquid)
    MethylmethacrylateComparable to Vertecem (99.3% ± 1%) & Spineplex (97.4%)98.5% ± 1%
    Dimethyl-paratoluidineComparable to Vertecem (0.7% ± 0.1%) & Spineplex (2.6%)1.5% ± 0.1%
    HydroquinoneComparable to Vertecem (20ppm± 5ppm) & Spineplex (75ppm)20ppm± 5ppm
    Physical Characteristics
    Molecular weights (Powder)Comparable to Vertecem (222,518 g/mole)534,511 g/mole
    Cured cementComparable to Vertecem (394 552 g/mole)646,966 g/mole
    Working phases @ 20°C (Mixing)Comparable to Vertecem (3 min)0.5 min
    Working phases @ 20°C (Waiting)Comparable to Vertecem (11.5 min)3 min
    Working phases @ 20°C (Application)Comparable to Vertecem (25 min)9 min
    Working phases @ 20°C (Setting time)Comparable to Vertecem (30 min)16 min
    Compressive strengthComparable to Vertecem (80.3 MPa)81.91 MPa
    Dynamic tension-compression mean fatigueComparable to Vertecem (4,317,676±1,237,780 cycles @ 7MPa) & Spineplex (3,799,425±1,990,989 cycles @ 7Mpa)4,627,970±847,458 cycles @ 7Mpa
    Bending strengthComparable to Vertecem (52.6 MPa)57.22 MPa
    Bending modulusComparable to Vertecem (4173 MPa)3338.82 MPa
    RadiopacityEquivalent radiopacity (Predicate)Equivalent radiopacity
    Monomer elution testingSimilar release profile to VertecemIncrease release till 10 minutes after mixing, then stabilization
    Compliance StandardISO 5833 "implants for surgery - acrylic resin cements"In compliance with ISO 5833.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Sample Size: Not specified for each individual non-clinical test. The document states "Test data indicate that the final properties of HIGH V+ are in compliance..." but does not detail the number of samples tested for each property (e.g., number of specimens for compressive strength).
    • Data Provenance: The tests were conducted by Teknimed, SAS, located in L'Union, France. The data appears to be prospective as it's part of the premarket submission for a new device.

    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)

    • Not applicable. This is a non-clinical (bench) study involving material properties, not diagnostic interpretation or clinical outcomes requiring expert ground truth.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not applicable. This is a non-clinical (bench) study.

    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. This is a non-clinical (bench) study about a bone cement, not an AI-assisted diagnostic device.

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

    • Not applicable. This is a non-clinical (bench) study of a physical material.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • For the non-clinical tests, the "ground truth" or reference for comparison is the established performance of legally marketed predicate devices (Vertecem, Spineplex) and the chemical/physical requirements outlined in the international standard ISO 5833 "Implants for surgery - acrylic resin cements."

    8. The sample size for the training set

    • Not applicable. This is a non-clinical study for a physical device, not a machine learning model requiring a training set.

    9. How the ground truth for the training set was established

    • Not applicable, as there is no training set for this type of device submission.
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    K Number
    K103433
    Device Name
    F20
    Manufacturer
    Date Cleared
    2011-01-03

    (40 days)

    Product Code
    Regulation Number
    888.3027
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K090435, K080873

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

    The F20 is indicated for the fixation of pathological fractures of the vertebral body using vertebroplasty or kyphoplasty procedures. Painful vertebral compression fractures of the vertebral body may result from osteoporosis, benign lesions (hemangioma), or malignant lesions (metastatic cancers, myeloma).

    Device Description

    F20 is a self-hardening and ready to use bone cement with a high amount of radiopaque agent for percutaneous vertebroplasty. Like its predicates F20 allows an excellent consolidation of the vertebral body and an effective and rapid pain relief. The cement is made of two sterile components: the polymer in powder and the liquid monomer. These two components are in a double sterile packaging. Each unit contains a sterile ampoule of liguid within a blister pack and a powder within a double peelable pouch, the whole being packaged in a box. The liquid component is mainly composed of methyl methacrylate. The major powder components are polymethylmethacrylate (PMMA). Benzoyl peroxide which initiates the polymerization is included in the polymer powder.

    AI/ML Overview

    The medical device described in the 510(k) summary is a bone cement called F20, intended for use in vertebroplasty and kyphoplasty procedures to fix pathological fractures of the vertebral body.

    Here's an analysis of the acceptance criteria and study information provided in the document:

    This document describes a non-clinical study for device F20 as depicted in the 510(k) summary provided.

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

    The F20 bone cement’s performance was evaluated against the standards outlined in ISO 5833 "Implants for surgery - acrylic resin cements". The acceptance criteria are implicitly defined by compliance with this standard and similarity to predicate devices.

    Acceptance Criteria (Implicit from ISO 5833 & Predicate Comparison)Reported Device Performance (F20)
    Chemical CompositionCompliant with ISO 5833, similar to predicate devices
    Powder MorphologyCompliant with ISO 5833, similar to predicate devices
    Molecular WeightsCompliant with ISO 5833, similar to predicate devices
    Handling TimesCompliant with ISO 5833, similar to predicate devices
    Compressive StrengthPerformed (per ISO 5833), compliant, similar to predicate devices
    Dynamic Fatigue Test (Compression)Performed, compliant, similar to predicate devices
    Flexural StrengthPerformed (per ISO 5833), compliant, similar to predicate devices
    Flexural ModulusPerformed (per ISO 5833), compliant, similar to predicate devices
    Viscosity or Extrusion Forces during Injection PhasePerformed, compliant, similar to predicate devices
    Setting Time vs. TemperaturePerformed, compliant, similar to predicate devices
    RadiopacityPerformed, compliant, similar to predicate devices (high amount of radiopaque agent specifically mentioned in description)
    Monomer Elution TestingPerformed, compliant, similar to predicate devices

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

    The document does not specify exact sample sizes for each non-clinical test (e.g., number of samples for compressive strength testing). It only states that tests were "conducted."

    The data provenance is from non-clinical laboratory testing conducted by Teknimed SAS, the manufacturer, in France. The specific nature of the data is experimental results from material science and mechanical engineering tests.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    This information is not applicable as there was no clinical study. The "ground truth" for the non-clinical tests would be the established scientific and engineering standards (ISO 5833) and the performance characteristics of the predicate devices. The experts involved would be the engineers and scientists conducting these tests, but their number and qualifications are not specified.

    4. Adjudication method for the test set

    This information is not applicable as there was no clinical study involving subjective interpretation. The assessment was based on objective measurements against ISO standards.

    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

    No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This device is a bone cement, not an AI-assisted diagnostic tool.

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

    No, this is not an AI algorithm. The performance evaluation was of the physical and chemical properties of the bone cement in a standalone non-clinical setting.

    7. The type of ground truth used

    The "ground truth" for the non-clinical tests was based on:

    • Established scientific and engineering standards: Specifically ISO 5833 "Implants for surgery - acrylic resin cements."
    • Performance characteristics of legally marketed predicate devices: Vertecem (K090435), Opacity+ (K080873), and Spine-Fix® (K045593). The F20 was shown to have similar properties to these predicates.

    8. The sample size for the training set

    This information is not applicable as this is not a machine learning or AI device. There is no concept of a "training set" for the evaluation of a bone cement's physical and chemical properties.

    9. How the ground truth for the training set was established

    This information is not applicable as this is not a machine learning or AI device.

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