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510(k) Data Aggregation
(318 days)
2.4mm Wise-Lock Distal Radius System:
2.4mm Wise-Lock Distal Radius System are used for displaced extra-articular distal radius fractures and corrective osteotomies of the distal radius.
2.4mm Wise-Lock Proximal Radius System:
2.4mm Wise-Lock Proximal Radius System are used for extra-articular fractures of Proximal radius and multifragmented radial neck fractures.
2.4mm Variable Angle Distal Radius System:
2.4mm Variable Angle Distal Radius System are used for displaced extra-articular and intra-articular distal radius fractures and corrective osteotomies of the distal radius.
The 2.4mm Radius System consists of various types of bone plates, screws for implantation in the radius bone to treat the radius bone fracture.
The provided text describes a 510(k) premarket notification for a medical device called the "2.4mm Radius System." This is a submission to the FDA demonstrating that a new device is substantially equivalent to a legally marketed predicate device, and thus does not require approval of a premarket approval application (PMA).
Crucially, this document focuses on demonstrating substantial equivalence based on design, materials, and mechanical performance tests against recognized standards, rather than clinical performance or diagnostic accuracy. Therefore, the concepts of acceptance criteria for diagnostic performance, test set characteristics, expert ground truth, MRMC studies, or standalone algorithm performance are not applicable to this type of regulatory submission.
The "acceptance criteria" in this context refer to compliance with material standards, mechanical performance standards, and sterilization/packaging standards. The "study that proves the device meets the acceptance criteria" refers to the non-clinical bench testing conducted against these standards.
Here's a breakdown of the requested information based on the provided text, noting where certain categories are not applicable:
Acceptance Criteria and Study Details for the 2.4mm Radius System (K211324)
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Criteria / Standard Met | Reported Device Performance |
---|---|---|
Material Standards | - ASTM F136/ISO 5832-3: Standard specification for wrought Titanium-6 Vanadium ELI (Extra low interstitial) Alloy for surgical implant applications. |
- ASTM F899-12: Standard Specification for Wrought Stainless Steels for surgical instruments.
- ASTM F138/ISO 5832-1: Standard Specification for Wrought-18 Chromium-14 Nickel-2.5 Molybdenum Stainless Steel Bar and Wire for Surgical Implants. | - Compliance verified with Titanium Alloy (Ti-6Al-4V) Grade 5 as per ISO 5832-1/ASTM F136 for Titanium Implants.
- Compliance verified with Stainless Steel (Grade 316L) as per ISO 5832-3/ASTM F138 for Stainless Steel Implants.
- Compliance verified with Grade 304 of Stainless steel (SS 304) Material for instruments as per ASTM F899-12b. |
| Mechanical Performance | - ASTM F382: Standard Specification and Test Method for Metallic Bone Plates. - ASTM F543: Standard Specification and Test Method for Metallic Medical Bone Screws. | Plate Testing:
- 4-Point Static Test: Conforms
- 4-Point Fatigue Test: Conforms
Screw Testing: - Driving Torque Test: Conforms
- Torsion Test: Conforms
- Axial Pull-out Test: Conforms |
| Biocompatibility | - ISO 10993-3 (General evaluation for raw materials) | Raw materials evaluated and found to comply with ISO 10993-3. |
| Sterilization & Packaging | - ISO 11137-1, -2, -3 (Radiation sterilization) - ISO 17665-1, -2, -3 (Moist heat sterilization)
- ISO 11140-1 (Chemical indicators)
- ISO 11737-1, -2 (Microbiological methods)
- ISO 11607-1, -2 (Packaging for sterile medical devices)
- ASTM F1980 (Accelerated Aging of Sterile Barrier Systems)
- ASTM F88/F88M (Seal strength)
- ASTM F1929 (Seal leaks by dye penetration) | Subject device and packaging validated against these standards for both Gamma Sterilization and non-sterile products. |
| Bacterial Endotoxin | - USP Bacterial Endotoxin Test. - USP Medical Devices-Bacterial Endotoxin and Pyrogen Tests. | Compliance with USP and for bacterial endotoxin and pyrogen tests. |
| Dimensional Verification | Comparison to predicate device dimensions. | Same dimension as of Predicate device. |
| Shelf-life | 5 Years | 5 Years (Same as predicate device) |
| Use Type | Single Use | Single Use (Same as predicate device) |
2. Sample size used for the test set and the data provenance
- Sample Size for Test Set: The document describes bench testing for mechanical integrity and material compliance, not clinical or diagnostic performance on human or animal subjects. The "sample size" would refer to the number of test coupons or devices subjected to mechanical tests (e.g., how many plates for 4-point static test, how many screws for torsion test). This specific number is not explicitly stated in the provided text, but it is implied that a sufficient number was tested to meet the requirements of the ASTM standards.
- Data Provenance (e.g., country of origin of the data, retrospective or prospective): The data provenance here refers to the origin of the bench test results. These tests were conducted as part of the manufacturer's (Auxein Medical Private Limited, India) submission to the FDA. The tests likely involved physical samples of the manufactured devices. The data itself is prospective in the sense that the tests were performed specifically for this submission against established standards.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not Applicable. This device is a bone fixation system (medical hardware), not a diagnostic algorithm that requires expert interpretation to establish a ground truth. The "ground truth" for this device relates to its material properties and mechanical performance, which are established by standardized laboratory testing methods and engineering specifications, not expert consensus on medical images or diagnoses.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
- Not Applicable. As this is not a diagnostic performance study, there's no need for an adjudication method for establishing ground truth. The compliance with standards is determined by objective measurements during bench testing.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, what was the effect size of how much human readers improve with AI vs without AI assistance
- Not Applicable. This is a bone fixation device, not an AI-assisted diagnostic tool. Therefore, MRMC studies and AI assistance comparisons are irrelevant to this submission.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not Applicable. This is a physical medical device (bone plate and screws), not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- The "ground truth" for this device is defined by established engineering and material standards (e.g., ASTM F382, ASTM F543, various ISO and ASTM material standards). Compliance with these standards confirms the device's functional and material integrity.
8. The sample size for the training set
- Not Applicable. This device is not an AI/machine learning algorithm, so there is no concept of a "training set."
9. How the ground truth for the training set was established
- Not Applicable. As there is no training set, this question is not relevant.
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(57 days)
The Emerge Medical Distal Radius Set is intended for fixation of complex intra-articular and extra-articular fractures and osteotomies of the distal radius and other small bones.
The Emerge Medical Distal Radius Set will include 6 and 9 locking hole head variations with pairs of locking and non-locking holes in the shafts to be used with a variety and screws to be FDA cleared and offered as a system of implants to be used for internal bone alignment and fixation of fractures of the radius. The system features plates with six and nine hole head variations with three and five hole shafts, bone screws for fixation, and a set of instruments to facilitate installation and removal of the implants. The plates have screw holes, which allow for attachment to the bones or bone fragments. The plates are fabricated from medical grade stainless steel (ASTM F139-12).
The provided document describes a 510(k) premarket notification for the "Emerge Medical Distal Radius Set," a device intended for bone fixation. However, the document does not contain the detailed information necessary to answer the questions about acceptance criteria and a study proving their fulfillment.
This type of submission (510(k)) typically focuses on demonstrating substantial equivalence to a predicate device, rather than proving performance against specific acceptance criteria through extensive clinical studies like those for novel devices or PMAs. The performance data presented is limited to non-clinical (FEA) testing.
Therefore, most of the requested information cannot be extracted from this specific document. Below is an attempt to answer what can be inferred from the provided text, and explicitly state what is missing.
Acceptance Criteria and Device Performance Study for the Emerge Medical Distal Radius Set
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria | Reported Device Performance |
---|---|
Mechanical Strength: Must be sufficient for intended use and substantially equivalent to legally marketed predicate devices. | Static and Dynamic Bending: Evaluated via Finite Element Analysis (FEA). Demonstrated that the predicate device (Synthes 2.4mm LCP Volar Column Distal Radius Plates K091644 and Synthes Locking Distal Radius Plating System K012114) was the "worst-case scenario." The results concluded that the strength of the Emerge Medical Distal Radius Set is sufficient for its intended use and substantially equivalent to predicate devices. |
Material: Must be medical grade and equivalent to predicate devices. | Fabricated from medical grade stainless steel (ASTM F139-12). Similar to predicate systems. |
Design, Sizes, Indications for Use: Must be similar to predicate systems without presenting new risks. | Has the same or similar design, sizes, and indications for use as predicate systems. Sizes differ slightly but present no new risks. |
Biocompatibility/Safety (implied): No new risks due to materials or design. | Fabricated from medical grade stainless steel (ASTM F139-12). No new risks identified from slight size differences or similar design. |
Missing Information:
- Specific numerical acceptance criteria for static and dynamic bending (e.g., minimum load capacity, maximum deformation) are not provided in the document.
- The exact numerical performance results (e.g., stress values, displacement) of the FEA for the Emerge Medical device or the predicate are not detailed. Only a qualitative "worst-case scenario" comparison and a conclusion of sufficiency are given.
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: Not applicable in the traditional sense of a clinical or human-subject test set. The performance evaluation was conducted using Finite Element Analysis (FEA), which is a computational method. It likely involved a digital model of the device.
- Data Provenance: Not applicable. FEA is a simulation method.
3. Number of Experts Used to Establish Ground Truth and Qualifications
- Not applicable. This study involved non-clinical FEA and did not rely on expert ground truth establishment for a test set. Design and engineering expertise would have been involved in setting up and interpreting the FEA.
4. Adjudication Method for the Test Set
- Not applicable. There was no human-reviewed test set requiring adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No. No MRMC comparative effectiveness study was conducted or mentioned. This device is a bone fixation appliance, not an imaging or diagnostic AI/ML device that would typically undergo such a study.
6. Standalone Performance Study (Algorithm only without human-in-the-loop performance)
- Yes, in spirit, but not an "algorithm" as typically conceived for AI/ML. The "standalone" performance here refers to the mechanical performance of the device itself, evaluated through FEA, without human interaction during the test. The FEA model computationally determined the device's mechanical characteristics.
7. Type of Ground Truth Used
- Engineering Principles and Predicate Device Data. For the FEA, the "ground truth" for comparison and validation would typically involve:
- Established biomechanical engineering principles.
- Material properties of medical-grade stainless steel (ASTM F139-12).
- Potentially, existing mechanical performance data or design specifications of the predicate devices for comparative analysis, although this is not explicitly detailed. The statement that the predicate was the "worst-case scenario" implies a comparison to known performance characteristics, either simulated or from prior testing.
8. Sample Size for the Training Set
- Not applicable. The performance evaluation was a non-clinical FEA, not an AI/ML algorithm that requires a training set. The FEA model itself is "designed" based on engineering specifications rather than "trained" on data.
9. How the Ground Truth for the Training Set Was Established
- Not applicable. There was no "training set" in the context of AI/ML. The FEA model's foundational data (material properties, geometry, boundary conditions) are established through engineering design, material science data, and biomechanical specifications.
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(112 days)
OsteoMed Wrist Plating System is intended for fracture fixation, fusion and osteotomies of wrist and other bones appropriate for the size of the device. It is intended for use in trauma, general surgery and reconstructive procedures.
OsteoMed Wrist Plating System implants are intended for single use only.
The OsteoMed Wrist Plating System is a rigid fixation and fusion system , consisting of plates and screws in various configurations along with the appropriate instrumentation to facilitate modification, implantation, or removal of the implants. Plates are anatomically pre-contoured in various shapes and sizes. Screws are provided with variable angle locking or non-locking head in various lengths. These screws are either solid core or cannulated and can be used with or without plates.
Plates and screws are supplied in a variety of configurations. The plates and screws are made of titanium alloy (ASTM F136). K-wires are made of titanium alloy (ASTM F136) or stainless steel (ASTM F138). The instrumentation is made from various grades of stainless steel, anodized aluminum, and/or medical grade polymers.
The provided text describes a 510(k) summary for the OsteoMed Wrist Plating System. This document focuses on demonstrating substantial equivalence to already legally marketed predicate devices, rather than conducting a de novo clinical study with specific acceptance criteria, sample sizes, and ground truth establishment for novel device performance.
Therefore, the requested information regarding acceptance criteria, a study proving device meeting these criteria, sample sizes, data provenance, expert ground truth, adjudication methods, MRMC studies, standalone performance, training set details, and ground truth establishment for the training set is not applicable or available within this 510(k) submission.
The document states:
- "Analyses of plate and screw strength were conducted to compare the OsteoMed Wrist Plating system components to predicate devices." This implies mechanical bench testing for equivalence, not a clinical study with performance metrics like sensitivity, specificity, or accuracy.
- "Equivalence for OsteoMed Wrist Plating system is based on similarities in intended use, design and operational principle to the referenced predicates. Based on the similarities, we believe that the OsteoMed Wrist Plating System does not raise any new safety or effectiveness issues." This is the core argument for a 510(k) submission.
Without a clinical study explicitly designed to measure performance against predefined acceptance criteria, it's impossible to populate the requested table and answer many of the questions.
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