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510(k) Data Aggregation
(90 days)
The CoLink® NeoFuse MIS Plating System is a fusion plate indicated for anterior fixation of ankle arthrodesis and fractures, including the distal tibia and talus. The addition of a posterior compression screw and a fully threaded screw through the tibiotalar joint (example CoLag 6.7mm screw) are required for ankle fusion procedure.
The CoLink® NeoFuse MIS Plating System includes sterile fusion plates and screws for anterior fixation of ankle arthrodesis and fractures, including the distal tibia and talus. The addition of a medial-lateral compression screw through the tibiotalar joint is required. These subject devices are a line extension of the CoLink® NeoFuse Plating System.
The provided text describes a medical device, the "CoLink® NeoFuse MIS Plating System," which is a fusion plate used for anterior fixation of ankle arthrodesis and fractures. This document is a 510(k) Pre-market Notification from the FDA, indicating a review of the device's substantial equivalence to existing legally marketed devices.
Based on the provided text, the following information can be extracted regarding the acceptance criteria and the study that proves the device meets them:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly present a table of numerical acceptance criteria with corresponding performance metrics like sensitivity, specificity, or AUC, as would be typical for an AI-powered diagnostic device. Instead, the "acceptance criteria" are implied by demonstrating substantial equivalence to predicate devices through various performance tests and comparisons.
The primary acceptance criteria for this type of medical device (a bone fixation system) revolve around:
- Mechanical Performance: The device must meet sufficient mechanical strength and fatigue properties to perform its intended function.
- Biocompatibility: The materials used must be safe for implantation in the human body.
- Sterility: The device must be sterile and maintain its sterility.
- Packaging Integrity: The packaging must protect the device and maintain sterility until use.
- Dimensional and Material Equivalence: The subject device's geometry, dimensions, and materials should be comparable to predicate devices.
Table of Performance (Based on provided text):
Performance Aspect | Acceptance Criteria (Implied by Substantial Equivalence to Predicates) | Reported Device Performance |
---|---|---|
Mechanical | The mechanical performance should be comparable to or better than predicate devices for bone fixation. Demonstrated adequacy through testing simulating in vivo loading conditions. (ASTM F382, modified). The device should withstand anticipated forces without failure and maintain stability for fixation. | "Testing was conducted per a modified ASTM F382 set up for the plates for the CoLink NeoFuse MIS Plating System and the plates were found to be substantially equivalent." "The test setup was modified from ASTM F382 to more accurately simulate anticipated mechanical loading on the plate in vivo." "No additional mechanical testing was required for the screws." (This implies the screws either meet requirements via predicate comparison or prior testing, which isn't detailed for the subject device.) |
Biocompatibility | The device materials must be biologically safe for human implantation. (ISO 10993-1). | "The CoLink NeoFuse MIS Plating System was validated per ISO 10993-1 for biocompatibility..." |
Sterilization | The device must be terminally sterilized and maintain sterility. Its sterilization method (gamma) must be validated to achieve a specified sterility assurance level (SAL). (ISO 11137-2). | "...ISO 11137-2 for gamma sterilization..." |
Packaging | The packaging must maintain product sterility and integrity until the point of use. (ISO 11607-1). | "...and ISO 11607-1 for packaging." |
Endotoxins | The device must have endotoxin levels below specified limits for implantable devices. (ANSI/AAMI ST72). | "Endotoxin testing was completed per ANSI/AAMI ST72." |
Material | Must use medical-grade materials suitable for implantation, comparable to predicate devices. | "Titanium Alloy (ASTM F136)" - Same as predicates. |
Intended Use & Indications for Use (IFU) | The subject device's intended use and Indications for Use should be substantially equivalent to the predicate devices, allowing for minor differences that do not raise new questions of safety or effectiveness. Minimal differences from predicate IFU regarding anatomical locations and required additional screws. | Subject device: "The CoLink® NeoFuse MIS Plating System is a fusion plate indicated for anterior fixation of ankle arthrodesis and fractures, including the distal tibia, talus, and calcaneus. The addition of a posterior compression screw and a fully threaded screw through the tibiotalar joint (example CoLag 6.7mm screw) is required." Predicate K213069: "...including the distal tibia, talus, and calcaneus. The addition of a compression screw through the tibiotalar joint (example CoLag 6.7mm screw) is required." (Minor difference: subject specifies "posterior compression screw and a fully threaded screw" vs. just "compression screw"). |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document does not provide numerical sample sizes for mechanical testing (e.g., number of plates tested). It states "Testing was conducted per a modified ASTM F382 set up for the plates...". For biocompatibility, sterilization, and packaging, it refers to validation according to international standards (ISO, ANSI/AAMI), which implies that appropriate sample sizes were used as dictated by those standards for validation studies, but these specific numbers are not detailed in this summary.
There is no mention of data provenance (e.g., country of origin or retrospective/prospective nature) as this is not a clinical study involving human patient data, but rather performance testing of the device itself.
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)
This is not applicable. The device is a physical bone fixation system, not a diagnostic AI device requiring expert ground truth for interpretation of medical images or patient outcomes. The "ground truth" for the mechanical performance testing would be the physical properties and failure points observed during the standardized tests, compared against established engineering and regulatory benchmarks.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable. Adjudication methods are relevant for studies involving human interpretation (e.g., of medical images) where discrepancies need to be resolved. This document details engineering and performance testing, not clinical interpretation.
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
This is not applicable. An MRMC study is relevant for AI-powered diagnostic devices that assist human readers. The CoLink® NeoFuse MIS Plating System is a surgical implant, not an AI diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
This is not applicable. This device is a physical implant, not an algorithm.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
The "ground truth" for this device's performance testing is based on:
- Standardized Test Methods: Adherence to and performance within established engineering standards (e.g., ASTM F382, ISO 10993-1, ISO 11137-2, ISO 11607-1, ANSI/AAMI ST72).
- Predicate Device Performance: The underlying assumption of substantial equivalence is that the predicate devices are safe and effective, and thus the subject device, performing comparably, is also considered safe and effective.
8. The sample size for the training set
This is not applicable. There is no "training set" as this device is not an AI algorithm requiring machine learning.
9. How the ground truth for the training set was established
This is not applicable for the same reason as above.
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(81 days)
The CoLink® NeoFuse Plating System is indicated for anterior fixation of ankle arthrodesis and fractures, including the distal tibia and talus.
The addition of a compression screw through the tibiotalar joint (example CoLag 6.7mm screw) is required.
The In2Bones CoLink® NeoFuse Plating System includes sterile fusion plates and screws for anterior fixation of ankle arthrodesis and fractures, including the distal tibia and talus. The addition of a medial-lateral compression screw through the tibiotalar joint is required. These subject devices are part of the overarching CoLink® Plating System and will be commonly referred to as the CoLink NeoFuse Plating System.
This is not an AI/ML device, so elements of the typical AI/ML acceptance criteria and study information are not applicable. The provided text describes a traditional medical device (metallic bone fixation system) and its regulatory clearance process, which focuses on demonstrating substantial equivalence to previously cleared predicate devices through performance testing and material comparisons.
Here's a breakdown based on the provided text, indicating where information is not applicable (N/A) for this type of device:
Device Name: CoLink® NeoFuse Plating System
510(k) Number: K213069
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (What was tested) | Reported Device Performance (Study Results) |
---|---|
Mechanical Performance: | |
- Plate mechanical strength (ASTM F382) | "Testing was conducted per a modified ASTM F382 set up for the plates for the CoLink® NeoFuse Plating System and the plates were found to be substantially equivalent." (Implies meeting or exceeding the performance of the predicate device under these testing conditions). |
- Screw mechanical performance (No new testing required) | "No additional mechanical testing was required for the screws." (Indicates screws are substantially equivalent based on prior clearances or material properties). |
Biocompatibility: | |
- Biocompatibility (ISO 10993-1) | "The CoLink® NeoFuse Plating System were validated per ISO 10993-1 for biocompatibility..." |
Sterilization: | |
- Gamma Sterilization (ISO 11137-2) | "...ISO 11137-2 for gamma sterilization..." |
Packaging: | |
- Packaging (ISO 11607-1) | "...and ISO 11607-1 for packaging." |
Endotoxins: | |
- Endotoxin testing (ANSI/AAMI ST72) | "Endotoxin testing was completed per ANSI/AAMI ST72." |
Material Composition: | |
- Material (Titanium Alloy ASTM F136) | "The subject CoLink® NeoFuse Plating System is made of Titanium Alloy..." (Matches predicate devices). |
Indications for Use: | |
- Equivalence of Indications for Use | The Indications for Use for the CoLink® NeoFuse Plating System are considered similar to the primary predicate K173121 – In2Bones SAS NeoFuse Ankle Fusion Plating System. |
Technological Characteristics (Design, Geometry): | |
- General design, dimensions, and screw types compared to predicates. | The device has "similarities and differences" in geometry and dimensions compared to predicates (e.g., available in 2 styles, 2 sizes each: Anterior and Anterolateral, 3 Hole and 5 Hole, Plate Length: 3.10in- 4.28in, Plate Thickness: .098in -.123in), but these were considered substantially equivalent. |
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: The document does not specify the exact number of plates or screws tested. It refers to "testing conducted per a modified ASTM F382 set up" for plates. For biocompatibility, sterilization, packaging, and endotoxin tests, these are typically conducted on representative samples of the device and its components, but specific sample numbers are not provided.
- Data Provenance: Not explicitly stated, but typically, these types of performance tests are conducted in a laboratory setting (e.g., by the manufacturer or a contract testing facility) in support of regulatory submissions. This is not clinical data, so terms like "retrospective" or "prospective" do not apply.
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)
- N/A. This is a hardware device review, not an AI/ML diagnostic or prognostic device that relies on ground truth established by experts interpreting clinical data. Ground truth in this context refers to the validated performance of the physical device under various engineering tests. Expert involvement would be in the design, testing methodology, and interpretation of engineering data, rather than clinical interpretation.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- N/A. Adjudication methods like 2+1 or 3+1 are typically used in clinical studies where multiple experts evaluate ambiguous cases or results for AI/ML performance evaluation. This device's evaluation is based on objective engineering tests and material comparisons.
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
- N/A. No MRMC comparative effectiveness study was performed as this is not an AI/ML device designed to assist human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- N/A. This is not an AI/ML algorithm. Its "performance" is assessed through physical and material testing, not through algorithmic output.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- Engineering Standards and Predicate Device Performance: The "ground truth" for this device's acceptance is based on its ability to meet established engineering standards (e.g., ASTM F382, ISO 10993-1, ISO 11137-2, ISO 11607-1, ANSI/AAMI ST72) and demonstrate "substantial equivalence" in mechanical properties, biocompatibility, sterilization, and function to previously cleared predicate devices. The performance of predicate devices against these standards serves as a benchmark.
8. The sample size for the training set
- N/A. This is not an AI/ML device, so there is no "training set."
9. How the ground truth for the training set was established
- N/A. As there is no training set for an AI/ML algorithm, this question is not applicable.
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(30 days)
The In2Bones USA LLC, CoLink® Cfx System is indicated for stabilization of fractures, revision procedures, osteotomies and reconstruction of the small bones in the foot and ankle including the calcaneus in both pediatric and adult patients.
The In2Bones CoLink® Cfx Plating System is a system of plates and screws and surgical instruments intended for stabilization of calcaneal fractures and osteotomies. These subject devices are part of the overarching CoLink® Plating System and will be commonly referred to as the CoLink® Cfx Plating System.
The provided FDA document, K200762, is a 510(k) premarket notification for a medical device (CoLink® Cfx Plating System) that aims to demonstrate substantial equivalence to previously cleared predicate devices. This type of submission relies on comparisons to existing devices rather than new clinical effectiveness or performance studies against specific acceptance criteria.
Therefore, the document does not contain the information required to populate the fields in your request, as it does not describe a study proving the device meets specific acceptance criteria in the way you've outlined.
Here's why and what information is available (and what is not):
- Acceptance Criteria & Reported Performance: Not applicable. The document focuses on demonstrating similarity to already approved devices.
- Sample Size, Ground Truth, Adjudication, MRMC, Standalone Studies: Not applicable. These relate to studies designed to evaluate a device's performance against a ground truth, which is not the purpose of this 510(k) submission.
- Training Set Sample Size & Ground Truth: Not applicable. This refers to AI/ML model development, which is not relevant to this mechanical implant device.
However, the document does provide the following relevant information about comparisons to predicate devices:
1. A table of acceptance criteria and the reported device performance
Criteria Category | Description from Document (Implicit "Acceptance" is Substantial Equivalence) | Performance (as described in the document) |
---|---|---|
Indications for Use | "stabilization of fractures, revision procedures, osteotomies and reconstruction of the small bones in the foot and ankle including the calcaneus in both pediatric and adult patients." | "The CoLink® Cfx Plating System has similar indications to the CoLink® Plating System (K163293) and Silverback Gorilla Plating System (K182148)." |
Material | (Implicitly, the material should be similar to predicates) | "made of Titanium Alloy" (Similar to K163293) |
Design/Geometry | (Implicitly, the geometry should be similar or justified as equivalent) | "This submission is adding additional plates for the calcaneus that will be used with previously cleared screws." "similar in geometry." |
Screws Compatibility | (Implicitly, compatibility with existing screws) | "The 3.5mm and 4.0mm screws initially cleared in the CoLink® Afx Plating System (K181113) can be used with the CoLink® Cfx Plating System." |
Mechanical Performance | (Implicitly, performance demonstrating equivalence to predicates in applicable mechanical tests.) The document refers to ASTM F382 (Standard Specification for Metallic Bone Plates for External Skeletal Fixation) for four-point bend testing. | "No additional mechanical testing was required for the CoLink® Cfx Plating System. The 3.5mm and 4.0mm screws are identical to previously cleared screws and no new worst-case plates were added. Engineering analysis was conducted related to the CoLink® Plating four-point bend testing performed per ASTM F382 to show the subject plates are substantially equivalent to the predicate plates." |
Sterilization | (Implicitly, the sterilization method should be validated or demonstrated to be covered by previous validations.) | "not a worst case for sterilization...was adopted into the previous validations for the CoLink® Afx System (K181113)." |
Biocompatibility | (Implicitly, the device should be biocompatible or demonstrated to be covered by previous validations.) | "not a worst case for...biocompatibility...was adopted into the previous validations for the CoLink® Afx System (K181113)." |
Shelf Life | (Implicitly, the shelf life should be validated or demonstrated to be covered by previous validations.) | "not a worst case for...shelf life...was adopted into the previous validations for the CoLink® Afx System (K181113)." |
Pyrogenicity | (Implicitly, the device should be non-pyrogenic or demonstrated to be covered by previous validations.) | "not a worst case for...pyrogenicity...was adopted into the previous validations for the CoLink® Afx System (K181113). Bacterial endotoxin testing (LAL) is performed on each lot." |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Not applicable. This document describes a 510(k) submission for a mechanical implant, not an AI/ML product or a product requiring a clinical "test set" in the context of effectiveness studies. The evaluations were based on engineering analysis and comparison to predicate devices, not patient data sets.
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. No ground truth established by experts for a test set is mentioned or required for this type of submission.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. No test set or adjudication process is described.
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 mechanical bone fixation system, not an AI-assisted diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
- Not applicable. This is a mechanical device, not an algorithm.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
- Not applicable. The "ground truth" in this context is the FDA's determination of substantial equivalence based on the provided engineering analysis and comparison to predicate devices.
8. The sample size for the training set
- Not applicable. This is a mechanical device, not an AI/ML product that uses a training set.
9. How the ground truth for the training set was established
- Not applicable. No training set is involved.
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(49 days)
The In2Bones USA LLC, CoLink® Plating System/CoLink® View Plating System/CoLink® Mini Plating System is indicated for stabilization and fixation of fractures, revision procedures, joint fusion, osteotomies and reconstruction of the small bones in the hand, wrist, foot and ankle in both pediatric and adult patients.
The In2Bones CoLink® Mini Plating System is a system of plates and screws and surgical instruments intended for stabilization of forefoot and midfoot fractures. These subject devices are part of the overarching CoLink® Plating System and will be commonly referred to as the CoLink® Mini Plating System.
This document is a 510(k) premarket notification from In2Bones USA, LLC for their CoLink® Mini Plating System. The FDA's letter and the company's 510(k) Summary confirm that the device is a metallic bone fixation appliance used for stabilization and fixation of fractures, revision procedures, joint fusion, osteotomies, and reconstruction of small bones in the hand, wrist, foot, and ankle for both pediatric and adult patients.
However, the provided text does not describe acceptance criteria or a study proving the device meets those criteria in the context of an AI/ML powered medical device. The document is for a traditional medical device (metallic bone plates and screws), and the "Performance Testing" section explicitly states that "No additional mechanical testing was required for the CoLink® Mini Plating System." Instead, it relies on engineering analysis and comparison to previously cleared predicate devices to demonstrate substantial equivalence, rather than a clinical performance study with defined acceptance criteria and human or algorithmic performance data.
Therefore, I cannot provide the requested information regarding acceptance criteria, device performance, sample sizes for test sets, expert ground truth establishment, adjudication methods, MRMC studies, standalone performance, or training set details, as these concepts are not relevant to the type of device and submission described in the provided text. The "Conclusion" section within the 510(k) Summary explicitly states: "Based on the test results and the comparison to the predicate devices, the subject device is determined to be substantially equivalent to the predicate devices." This highlights that the basis for clearance is substantial equivalence to existing devices, not a new performance study against specific acceptance criteria.
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