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510(k) Data Aggregation

    K Number
    K201656
    Date Cleared
    2020-09-15

    (89 days)

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

    K170705, K170313, K171285, K172008

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

    The ARIX Elbow System is intended for fractures and osteotomies of proximal radius, ulnar olecranon and distal humerus. The ARIX Proximal Radius Plate is intended for use in proximal radial fractures and osteotomies. The ARIX Olecranon Plate is intended for use in particular for ulna fractures and osteotomies. The ARIX Distal Humerus Plate is intended for use in distal humerus fractures, osteotomies and non-unions.

    Device Description

    The ARIX Elbow System is consist of proximal radius plate, ulna olecranon plate, distal humerus plate and bone screw. The ARIX Elbow System is made of Unalloyed Titanium Alloy (Ti-6AL-4V), which meet ASTM F67, Standard Specification for Unalloyed Titanium for Surgical Implant Applications, and ASTM F136, Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications, which are widely used for surgical implants with well-known biocompatibility. The plates vary essentially through different type and number of plate holes. The screws vary essentially through different lengths and diameters. It also includes various manual surgical instruments such as drill bits, drill sleeve and sleeve handle, driver, depth gauge, bender, handle, driver shafts and depth gauge. The ARIX Elbow System not provided sterile. It is required to be sterilized via autoclave method to reach a SAL of 10-6 by the hospital prior to surgery. The sterilization method is presented in the instruction, which was validated per ISO 17665-1: 2006 Sterilization of health care products - Moist heat - Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices.

    AI/ML Overview

    This looks like a 510(k) premarket notification for a medical device called the "ARIX Elbow System," which is a metallic bone fixation appliance. It is important to note that this document is for a physical medical device (bone plates and screws), not a software or AI-based diagnostic device. Therefore, the questions about acceptance criteria, study design for AI performance metrics (like sensitivity, specificity, MRMC studies, ground truth establishment, etc.), and training/test set sample sizes as typically applied to AI/ML devices do not directly apply in the context of this 510(k) summary.

    However, I can extract information related to the device's performance justification based on the provided document, adapting your questions to fit the context of a physical orthopedic implant.

    Here's an analysis based on the provided text, indicating where the requested information is not applicable for this type of device:


    1. Table of Acceptance Criteria and Reported Device Performance

    For this physical device, "acceptance criteria" and "performance" are typically demonstrated through adherence to recognized national/international standards for mechanical properties and biocompatibility, and through comparison to predicate devices.

    Acceptance Criteria (Demonstrated via Standards & Benchmarking)Reported Device Performance (Summary of Test Results)
    Biocompatibility: Meet requirements for materials used in surgical implants to ensure no adverse biological reactions (implied by material selection meeting ASTM standards).The ARIX Elbow System is made of Unalloyed Titanium Alloy (Ti-6AL-4V), which meet ASTM F67 (Standard Specification for Unalloyed Titanium for Surgical Implant Applications) and ASTM F136 (Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI Alloy for Surgical Implant Applications). These are widely used, biocompatible materials for surgical implants.
    Mechanical Strength & Performance (Bone Screws): Must meet specified mechanical properties for metallic medical bone screws (e.g., torsional strength, pull-out strength, bending strength).Non-Clinical Test was conducted to verify that the subject device met all design specifications. The test result demonstrated that the subject device complies with ASTM F543 (Standard Specification and Test Method for Metallic Medical Bone Screws). The results indicate that the ARIX Elbow System is equivalent to the predicate device in terms of screw performance.
    Mechanical Strength & Performance (Bone Plates): Must meet specified mechanical properties for metallic bone plates (e.g., fatigue strength, static bending strength, stiffness).Non-Clinical Test was conducted to verify that the subject device met all design specifications. The test result demonstrated that the subject device complies with ASTM F382 (Standard Specification and Test Method for Metallic Bone Plates). The results indicate that the ARIX Elbow System is equivalent to the predicate device in terms of plate performance.
    Sterilization Efficacy: Demonstrate that the recommended sterilization method achieves the required sterility assurance level (SAL).The sterilization method (autoclave) in the instruction was validated per ISO 17665-1: 2006 (Sterilization of health care products - Moist heat - Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices) to reach a SAL of 10-6.
    Substantial Equivalence: Demonstrate that the device is as safe and effective as a legally marketed predicate device, with similar indications for use, technological characteristics, operating principles, design features, performance, biocompatibility, materials, and method of sterilization. This is a core regulatory acceptance criterion for 510(k) clearance.The ARIX Elbow System has the same: Indication for Use, Technological characteristics, Operating principle, Design features, Performance, Biocompatibility, Materials, and Method of sterilization when compared to the predicate devices (K090053, K103332, K112560 and K063049). It is concluded to be substantially equivalent in design, material, and function. "There are no significant differences between the subject device and the predicate devices that would adversely affect the use of the product."

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

    • Sample Size: Not applicable in the traditional sense of a "test set" for an AI/ML algorithm. The "test" here refers to non-clinical (bench) testing of the physical device components. For non-clinical tests, the sample size would typically be a small number of representative devices tested according to the respective ASTM standards (e.g., typically N=5 to 10 for mechanical tests, per standard guidelines). The document does not specify the exact number of units tested for each non-clinical test.
    • Data Provenance: Not applicable for a non-AI physical device. The "data" comes from controlled laboratory bench tests adhering to international standards.

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

    • Not Applicable. This is a physical orthopedic implant. There is no "ground truth" in the context of expert review for an AI/ML diagnostic output. Device performance is assessed via objective, quantifiable mechanical and material properties or sterilization efficacy, measured against established standards.

    4. Adjudication Method for the Test Set

    • Not Applicable. See point 3.

    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 physical device, not an AI/ML diagnostic or assistive tool for human readers. No MRMC study was performed or is relevant.

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

    • Not Applicable. This is a physical device, not an algorithm.

    7. The Type of Ground Truth Used

    • Not Applicable in the AI/ML context. For this device, "ground truth" or verification is based on:
      • Objective Measurement against Bending/Torsional/Tensile Strength Standards: Mechanical properties (e.g., measured force, displacement, cycles to failure, pull-out strength, fatigue life) determined via bench testing per ASTM F543 and F382.
      • Material Composition/Purity Specifications: Verification that the materials meet ASTM F67 and F136.
      • Sterility Assurance Level (SAL): Verification that the sterilization process achieves a 10^-6 SAL per ISO 17665-1.
      • Comparison to Predicate Device: Demonstrating similar characteristics and performance to already cleared devices.

    8. The Sample Size for the Training Set

    • Not Applicable. This is a physical device, not an AI/ML model that requires a training set.

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

    • Not Applicable. See point 8.

    Summary of Device Justification from the Document:

    The ARIX Elbow System demonstrated its "acceptance criteria" and "performance" through:

    • Material Compliance: Use of medical-grade titanium alloys (Ti-6AL-4V) meeting ASTM F67 and F136, indicating known biocompatibility.
    • Non-Clinical Bench Testing: Demonstrated compliance with ASTM F543 (for screws) and ASTM F382 (for plates), ensuring the devices meet established mechanical performance standards for bone fixation. The results indicated equivalence to the predicate device.
    • Sterilization Validation: Validation of the recommended autoclave sterilization method to achieve the required 10^-6 SAL per ISO 17665-1, ensuring the product can be safely prepared for surgery.
    • Substantial Equivalence: A direct comparison to identified predicate devices (Medartis AG APTUS systems and Synthes Modular Mini Fragment LCP System) confirmed similarities in indications for use, technological characteristics, operating principle, design features, expected performance, biocompatibility, materials, and sterilization methods. No significant differences affecting safety or effectiveness were identified.
    • No Clinical Studies: The submission explicitly states, "No clinical studies were considered necessary and performed," which is common for 510(k) submissions where substantial equivalence can be demonstrated through non-clinical data.
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