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510(k) Data Aggregation
(449 days)
The P300 Attachment is intended to be used with electric and pneumatic surgical instruments and cutting accessories for cutting, drilling, removal, and shaping of bone in the procedures of: Neuro, Spine, Orthopedic, and General Surgery.
NSK Sterile Cutting Accessory(ies) is for single use only. This device is intended for use, in conjunction with P300 Attachment, in cutting, drilling, removal, and shaping of bone in the procedures of: Neuro, Spine, Orthopedic, ENT, Maxillofacial, and General Surgery.
The P300 Attachment is a powered bone cutting and drilling instruments designed to be used with the Primado2 Total Surgical System (K132264), which provides mechanical power to the attachment. The P300 Attachment is comprised of two families: Standard Attachment 300 and Slim Attachment 300. The Standard Attachment 300 and Slim Attachment 300 consist of angled and straight types of attachments with varying lengths. The Standard Attachment 300 is an attachment to the Primado2 Total Surgical System that can be in either a straight or angled configuration and comes in 5 different tube lengths, ranging from 12 mm to 79 mm. Accessories compatible with the Standard Attachment 300 include 52 NSK Sterile Cutting Accessories, a STD Attachment Beak, and 4 Irrigation Nozzles. The Slim Attachment 300 consists of 2 parts, a Slim Attachment Hub that comes in 2 configurations (straight or angled) and a Slim Tube that comes in 8 configurations and varies in tube lengths from 110 mm to 240 mm, and can be straight, curved, or angled. Accessories compatible with the Slim Attachment 300 include 49 NSK Sterile Cutting Accessories, a Slim Tube Beak and a Slim Tube Hood, and 2 Irrigation Nozzles. The Standard Attachment 300 and Slim Attachment 300 share the same Cleaning Tools for automated cleaning, manual cleaning, and purging. For both the Standard Attachment 300 and the Slim Attachment 300, the length of the bur can be adjusted in six levels. Both the Standard and Slim attachments include a non-slip surface etching on the grip. The attachments consist of stainless steel, polytetrafluoroethylene, Copper-Beryllium Alloy, fluorocarbon rubber, and PEEK.
Here's an analysis of the acceptance criteria and study information for the P300 Attachment and NSK Sterile Cutting Accessories, based on the provided FDA 510(k) summary:
This device is not an AI/ML device, but a surgical attachment. Therefore, most of the requested AI/ML specific criteria (sample size for test set, data provenance, number of experts, adjudication, MRMC study, standalone performance, training set size and ground truth establishment for training set) are not applicable.
Acceptance Criteria and Reported Device Performance
The device appears to be a traditional medical device (Powered Simple Cranial Drills, Burrs, Trephines, and Their Accessories), and the FDA 510(k) summary focuses on demonstrating substantial equivalence to a predicate device through non-clinical bench testing, rather than a clinical study with traditional acceptance criteria for diagnostic performance metrics (e.g., sensitivity, specificity, AUC).
The acceptance criteria are implied by the successful completion of specific non-clinical tests and demonstrations of compliance with relevant standards. The "performance" section describes the results of these tests, which effectively serve as the reported device performance meeting the implicit acceptance criteria of the standards and internal specifications.
Acceptance Criteria (Implied) | Reported (Met) Device Performance |
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Biocompatibility: | |
- Non-cytotoxic (ISO 10993-5) | - Cell culture treated with test sample exhibited slight reactivity (Grade 1), and after maximum cleaning/disinfection cycle, exhibited no reactivity (Grade 0). Concluded as Non-cytotoxic. |
- Non-sensitizing (ISO 10993-10) | - Test article extracts showed no evidence of causing delayed dermal contact sensitization. Concluded as Non-sensitization. |
- Non-irritating (Intracutaneous Reactivity Test, ISO 10993-10) | - All animals appeared normal throughout the study. All injection sites appeared normal immediately following injection. Concluded as Non-irritability. |
- Non-toxic (Acute Systemic Toxicity Test, ISO 10993-11) | - No mortality or evidence of systemic toxicity from the extracts injected into mice. Concluded as Non-toxic. |
- Non-pyrogenic (Material-Medicated Pyrogenicity Test, ISO 10993-11) | - Total rise of rabbit temperatures during the 3-hour observation period was within acceptable USP requirements. Met requirements for absence of pyrogens. Concluded as Non-pyrogenic. |
- Non-hemolytic (ASTM F756 & ISO 10993-4) | - Hemolytic index for the test article extract indicated the hemolytic grade was within the non-hemolytic range. Concluded as Non-hemolytic. |
Reprocessing: | |
- Compliance with reprocessing standards (ISO 17664, ISO 17665-1, | - Testing demonstrated compliance to applicable standards for reprocessing (ISO 17664:2017, ISO 17665-1:2006, ANSI/AAMI ST79:2017). |
ANSI/AAMI ST79) | |
Sterilization: | |
- Compliance with sterilization standard (ISO 11137-2) | - Testing demonstrated compliance to the applicable standard for sterilization (ISO 11137-2:2013). |
Functional Performance: | |
- Meet internal functional specifications | - Verification/validation testing to internal functional specifications demonstrated that the device is as safe and effective as the predicate device. The conclusion states "non-clinical bench performance testing data support the safety of the P300 Attachment and the NSK Sterile Cutting Accessories and the verification and validation demonstrate that the P300 Attachment and NSK Sterile Cutting Accessories are as safe and effective as the predicate and reference devices and performs as intended in the specified use conditions." |
- Maximum Rotation: 80,000 min-1 | - Reported as 80,000 min-1 (Identical to predicate). |
Study Information
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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 applicable. The "test set" in this context refers to samples used for non-clinical bench testing (e.g., cell cultures, animal models for biocompatibility, physical device units for functional testing). Specific numbers for these types of samples are not provided in the summary. For example, for the "Acute Systemic Toxicity Test," it mentions "mice" but not the count. The biocompatibility testing selected "worst-case representative models" (Slim Attachment 300, specific bur/nozzle models) for evaluation.
- Data Provenance: The manufacturing site for NAKANISHI INC. is listed as Kanuma, Tochigi 322-8666 Japan. The tests would likely have been conducted by or for the manufacturer. The FDA 510(k) summary does not specify the country of origin for the testing facilities, but it typically aligns with the manufacturer's region or accredited labs. All testing is prospective in nature, as it's conducted specifically for demonstrating the safety and effectiveness of the device being submitted.
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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 submission for a surgical instrument. "Ground truth" in the context of expert consensus, as might be used for AI diagnostic devices, is not a concept applied here. The "truth" is established by adherence to recognized international and national standards (e.g., ISO, ASTM, ANSI/AAMI) for material safety, reprocessing, and sterilization, verified through laboratory testing.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. Adjudication methods are typically relevant for clinical studies or studies involving human interpretation of data where consensus is needed to establish ground truth for a diagnostic outcome. This submission relies on objective physical, chemical, and biological testing results.
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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:
- No. This is a non-clinical submission for a mechanical surgical instrument. MRMC studies are used for evaluating the performance of AI/CADe diagnostic devices in conjunction with human readers.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- No. This device does not have an algorithm or AI component.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- For this device, the "ground truth" is defined by established scientific and engineering principles, as articulated in national and international standards (e.g., ISO 10993 for biocompatibility, ISO 17664/17665/ANSI/AAMI ST79 for reprocessing, ISO 11137-2 for sterilization). Compliance with these standards, demonstrated through specific laboratory tests (e.g., cytotoxicity assays, sensitization tests, pyrogenicity tests, material characterization), serves as the evidence that the device is safe and performs as intended.
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The sample size for the training set:
- Not applicable. This device does not use an AI/ML algorithm that requires a training set.
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How the ground truth for the training set was established:
- Not applicable, as there is no training set for an AI/ML algorithm.
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