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510(k) Data Aggregation
(81 days)
T-Button® A Adjustable Loop UHMWPE Suture PEEK Button, Close Button & T-Button® S Adjustable Loop UHMWPE Suture PEEK Button, Open Button are to be used for fixation of bone or soft tissue to bone, and are intended as fixation posts, a distribution bridge, or for distributing suture tension over areas of ligament or tendon repair. This device is employed in Knee ligament repair and reconstructive procedures, specifically for ACL/PCL repair and reconstruction.
The T-Button® A Adjustable Loop UHMWPE Suture PEEK Button, Close Button & T-Button® S Adjustable Loop UHMWPE Suture PEEK Button, Open Button is a permanently implantable Polyether Ether Ketone (PEEK) cortical tibial suspension fixation device which provides the orthopaedic surgeon a means of accurate fixation in ligament reconstructive surgeries and repair. The fixation device allows for endoscopic or open ligament reconstruction approaches. The Closed button is preloaded with UHMWPE adjustable loop and in Open Button the UHMWPE adjustable loop is non preloaded.
This is a 510(k) premarket notification for a medical device called the T-Button® A Adjustable Loop UHMWPE Suture PEEK Button, Close Button and the T-Button® S Adjustable Loop UHMWPE Suture PEEK Button, Open Button. This document does not describe a study involving AI or human readers. Instead, it focuses on demonstrating the substantial equivalence of the new device to existing predicate devices through non-clinical performance testing and material comparisons.
Therefore, many of the requested sections related to AI performance, such as sample sizes for test and training sets, data provenance, number and qualifications of experts, adjudication methods, MRMC studies, and standalone algorithm performance, are not applicable to this type of device submission.
Here's the information that can be extracted from the provided text regarding the device's acceptance criteria and the study proving it meets them:
1. A table of acceptance criteria and the reported device performance:
Acceptance Criteria / Performance Test | Reported Device Performance | Comments |
---|---|---|
Mechanical Performance | ||
Pull-Out Testing | The results were found equipotent (equivalent) to the primary predicate (Arthrex ACL TightRope®) and reference predicate (ANCHORMAN Tibial Ligament Fixation Device), defining the strength of the suture button to hold the loop. The acceptance criteria was met. | Similar performance to predicate devices. |
Cyclic Loading | The results were found equipotent (equivalent) to the primary predicate (Arthrex ACL TightRope®) and reference predicate (ANCHORMAN Tibial Ligament Fixation Device). The acceptance criteria was met. | Similar performance to predicate devices. |
Biocompatibility | ||
Skin Sensitization (Guinea Pig Minimization Test) | Non-Sensitizer | Meets biocompatibility standards. |
Intracutaneous Reactivity Test | Non-Reactive | Meets biocompatibility standards. |
Material Mediated Pyrogenicity | Non-Pyrogenic | Meets biocompatibility standards. |
Acute Systemic Toxicity Test | Did not Induce any Systemic Toxicity | Meets biocompatibility standards. |
In vitro Cytotoxicity Test: Elution Method | Non-Cytotoxic | Meets biocompatibility standards. |
Bone Implantation Studies (PEEK Rods) | Minimal or No Reaction | Meets biocompatibility standards. |
Bone Implantation Studies (UHMWPE Suture) | Minimal or No Reaction | Meets biocompatibility standards. |
Intramuscular Implant (PEEK) | Minimal or No Reaction | Meets biocompatibility standards. |
Other Safety/Performance Tests | ||
Sterilization Validation | Not explicitly detailed, but stated as "performed to support the demonstration of substantial equivalence." (Sterilization method is ETO, similar to predicate device.) | Assumed to meet industry standards. |
Shelf-Life | 5 Years (Similar to predicate device). Not explicitly detailed, but stated as "performed to support the demonstration of substantial equivalence." | Assumed to meet industry standards. |
Endotoxin Monitoring | Not explicitly detailed, but stated as "performed to support the demonstration of substantial equivalence." (Bacterial Endotoxin testing stated for safety data, similar to predicate.) | Assumed to meet industry standards. |
Pyrogenicity Testing | Not explicitly detailed, but stated as "performed to support the demonstration of substantial equivalence." (Material Mediated Pyrogenicity testing stated for safety data.) | Assumed to meet industry standards. |
Specifications and Dimensions | Changes in dimensions (16mm x 7.5mm for subject device button vs. 13mm x 3.3mm x 1.5mm for primary predicate) were observed not to lead to any new risks with performance, and acceptance criteria were met in each performance test. (Loop Length: 90 mm, similar to predicate). | Device design differences (larger button) do not negatively impact performance as per testing. |
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 explicitly stated in the document. The document refers to "bench testing" and "studies" but does not quantify the number of devices tested for mechanical or biocompatibility assessments.
- Data Provenance: The studies are non-clinical (bench testing, in vitro, and in vivo animal studies for biocompatibility). India (Healthium Medtech Limited is based in Bangalore, India) is the location of the manufacturer and presumably where these tests were conducted or commissioned. The data is prospective, generated specifically for this submission.
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 physical medical device. "Ground truth" in this context refers to the validated methods and resulting measurements from mechanical and biological tests, not expert interpretation of data. These tests would be conducted by qualified laboratory personnel and validated against international standards.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not Applicable. As above, this is not an interpretive diagnostic device. Test results are quantitative measurements against predetermined specifications and international 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:
- Not Applicable. This device is a physical implant for orthopedic surgery, not an AI-powered diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- Not Applicable. This is a physical medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For mechanical performance (Pull-Out, Cyclic Loading): Quantitative measurements of force, displacement, and cycles against predefined specifications and industry standards. The "ground truth" is that the device must withstand certain loads and cycles without failure, demonstrating "equipotent" performance to predicate devices.
- For biocompatibility: Adherence to international standards (e.g., ISO 10993) for biological evaluation of medical devices, using in vitro and in vivo (animal) models to assess toxicity, sensitization, pyrogenicity, and tissue reaction. The "ground truth" is the observation of "non-sensitizer," "non-reactive," "non-pyrogenic," "non-cytotoxic," and "minimal or no reaction" based on established biological endpoints.
8. The sample size for the training set:
- Not Applicable. This is a physical medical device, not an AI model requiring a training set.
9. How the ground truth for the training set was established:
- Not Applicable. As above, no training set for an AI model. For the device itself, the "ground truth" for its design and manufacturing is established through engineering specifications, material standards, and compliance with quality management systems.
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