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510(k) Data Aggregation

    K Number
    K132502
    Device Name
    VARIAX 2 SYSTEM
    Manufacturer
    Date Cleared
    2013-10-23

    (75 days)

    Product Code
    Regulation Number
    888.3030
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Stryker VariAx 2 System is intended for internal bone fixation in adult patients.

    The Stryker VariAx 2 System screws, when used in conjunction with VariAx Plating Systems; or used independently in a lag screw technique, are indicated for:

    • Internal fracture fixation;
    • Osteotomies:
    • Revision procedures such as non-unions or mal-unions;

    In addition, the following indications are specific to the devices listed below:

    • T8 2.4mm Screws & T8 2.0mm Locking Peg: For use in small bones, primarily including the Distal Radius, in the treatment of:
      • Compression fractures:
      • Intra-articular and extra-articular fractures;
      • Displaced fractures;
      • Reconstruction procedures;
    • T8 2.7mm Screws: For use in small bones, including the Distal Radius as well as the fore, midand hind Foot and Ankle, in the treatment of:
      • Intra-articular and extra-articular fractures of the Distal Radius,
      • Displaced and compression fractures of the Distal Radius;
      • Replantation, joint fusions or arthrodesis and corrective osteotomies in the Foot & Ankle;
      • Reconstruction procedures in the Foot & Ankle and Distal Radius:
    • T10 3.5mm and T10 2.7mm Screws: For use in the Radius, Ulna, Clavicle, Humerus, Foot and Ankle, Distal Tibia and Fibula, in the treatment of:
      • Intra-articular and extra-articular fractures of the Distal Humerus and Proximal Ulna:
      • Single, segmental and comminuted fractures;
      • Replantation, joint fusions or arthrodesis and corrective osteotomies in the Foot & Ankle:
      • Normal bone density or osteopenic bone.
    Device Description

    The VariAx 2 System is an internal fixation device consisting of screws and instrumentation that will be used in conjunction with previously cleared VariAx Plating Systems to treat a number of different types of fractures in the radius, ulna, humerus, clavicle, foot, and fibula. These screws can be used in conjunction with said plating systems, or in the case of non-locking screws, may also be used independently using a lag screw technique. The subject components will be available sterile and non-sterile.

    AI/ML Overview

    The VariAx 2 System is a medical device designed for internal bone fixation. Its acceptance was determined through non-clinical laboratory testing, demonstrating substantial equivalence to previously cleared predicate devices.

    1. Acceptance Criteria and Reported Device Performance:

    Test PerformedAcceptance CriteriaReported Device Performance
    Screw Pull-Out TestingPerformance comparable to predicate devicesSubstantially equivalent to predicate devices
    Screw Shear-Off TestingPerformance comparable to predicate devicesSubstantially equivalent to predicate devices
    Screw Insertion Torque TestingPerformance comparable to predicate devicesSubstantially equivalent to predicate devices
    Static Cantilever Bending of Locking MechanismPerformance comparable to predicate devicesSubstantially equivalent to predicate devices
    Dynamic Fatigue Plate-Screw Construct TestingPerformance comparable to predicate devicesSubstantially equivalent to predicate devices

    Note: The document does not provide specific numerical values for the acceptance criteria or reported performance. The "acceptance criteria" and "reported device performance" are inferred from the statement "Testing demonstrated that the VariAx 2 System is substantially equivalent to the predicate devices currently cleared for marketing."

    2. Sample Size and Data Provenance for Test Set:

    • Sample Size: The document does not specify the sample size used for each non-clinical test.
    • Data Provenance: Not applicable as the testing was non-clinical laboratory testing. The country of origin for the sponsor, Stryker Trauma AG, is Switzerland.

    3. Number and Qualifications of Experts for Ground Truth:

    Not applicable. The regulatory pathway for this device (510(k)) focuses on substantial equivalence through non-clinical testing for fracture fixation systems, not on human expert assessment for image interpretation or diagnosis. Therefore, no experts were used to establish ground truth in the context of image interpretation.

    4. Adjudication Method for Test Set:

    Not applicable. This was a non-clinical device testing study, not a clinical study involving human judgment or interpretation requiring adjudication.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

    No, a multi-reader multi-case (MRMC) comparative effectiveness study was not performed. The submission explicitly states, "Clinical testing was not required for this submission."

    6. Standalone Performance Study:

    Yes, in a way. The non-clinical laboratory tests assess the performance of the device components (screws and plate-screw constructs) in isolation, under controlled laboratory conditions, to determine their mechanical properties and functional equivalence to predicate devices. This represents an "algorithm only without human-in-the-loop performance" in the context of a physical device's mechanical integrity.

    7. Type of Ground Truth Used:

    The ground truth used for proving the device meets acceptance criteria was based on engineering and mechanical performance benchmarks established by predicate devices and recognized industry standards for bone fixation appliances. These benchmarks are inherently quantitative and objective, derived from physical testing.

    8. Sample Size for the Training Set:

    Not applicable. This device is a physical bone fixation system, not an AI/ML algorithm. Therefore, there is no "training set" in the context of machine learning.

    9. How the Ground Truth for the Training Set Was Established:

    Not applicable, as there is no training set for this type of medical device submission.

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    K Number
    K130116
    Manufacturer
    Date Cleared
    2013-03-05

    (48 days)

    Product Code
    Regulation Number
    888.3030
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K113760

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

    The Variax Clavicle System is intended for use in internal fixation in the clavicle.

    The Variax Clavicle Anterior/Superior Lateral and Anterior/Superior Midshaft Plates are indicated for fixation of single, segmental and comminuted fractures, osteotomies, mal-unions, and non-unions of the clavicle.

    Device Description

    The Variax Clavicle System consists of anatomically contoured Anterior and Superior Lateral Plates as well as Anterior and Superior Midshaft Plates which were previously cleared in K113760. The plates are manufactured from Titanium alloy per ASTM F136 and Commercially Pure Titanium per ASTM F 67. The plates are fixed to the clavicle using 3.5mm or 2.7mm locking or non-locking screws. This Special 510(k) submission is intended to introduce 145mm Superior Lateral Plates as a line extension to the currently marketed Superior Lateral Plates in the Variax Clavicle System. This will extend the range of plate sizes from 74mm-145mm in length.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study details for the Variax Clavicle System, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance CriterionReported Device PerformanceStudy that Proves Device Meets Criteria
    Material EquivalencePlates are manufactured from Titanium alloy per ASTM F136 and Commercially Pure Titanium per ASTM F67.Risk analysis per ISO 14971:2007; comparison to predicate device (K113760).
    Design EquivalenceAnatomically contoured Anterior and Superior Lateral Plates, as well as Anterior and Superior Midshaft Plates. Extension of plate size range (74mm-145mm).Risk analysis per ISO 14971:2007; comparison to predicate device (K113760).
    Operational Principle EquivalenceFixes to the clavicle using 3.5mm or 2.7mm locking or non-locking screws.Risk analysis per ISO 14971:2007; comparison to predicate device (K113760).
    Safety and Effectiveness EquivalenceThe new plate length did not present a new worst case. Met performance requirements and are as safe and effective as their predicate devices.Risk analysis per ISO 14971:2007; "same verification and validation methods were applied to the subject device in comparison to the previously cleared predicate (K113760)".
    Intended Use EquivalenceInternal fixation in the clavicle for various fracture types, osteotomies, mal-unions, and non-unions.Comparison to predicate device (K113760) (stated in Substantial Equivalence section).

    2. Sample Size Used for the Test Set and Data Provenance

    The provided document does not specify a patient-based "test set" or its sample size, nor data provenance (country of origin, retrospective/prospective). The evaluation appears to be based on an engineering risk analysis and comparison to a predicate device rather than a clinical study with patient data.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications

    This information is not applicable as there is no mention of a clinical test set requiring expert ground truth establishment. The evaluation relies on engineering principles and comparison to a predicate.

    4. Adjudication Method for the Test Set

    This information is not applicable as there is no clinical test set requiring adjudication.

    5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size

    No, an MRMC comparative effectiveness study was not done. The submission focuses on substantial equivalence to a predicate device through non-clinical testing.

    6. If a Standalone (i.e. algorithm only without human-in-the loop performance) Was Done

    Not applicable. This device is a bone fixation system, not a software algorithm or AI-powered diagnostic tool. The submission details a medical device, not a digital health product that would have standalone performance.

    7. The Type of Ground Truth Used

    For this medical device, the "ground truth" is established through engineering principles, material standards (ASTM F136, ASTM F67), risk assessment (ISO 14971:2007), and direct comparison to the design and performance of a previously cleared predicate device (K113760).

    8. The Sample Size for the Training Set

    Not applicable. This submission describes a physical medical device (bone fixation system), not an AI/ML algorithm that would require a training set.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable. As established in point 8, there is no training set for this type of device.

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