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510(k) Data Aggregation
(56 days)
Versalock Upper Limb Plating System are intended to be used for internal bone fixation for bone fractures, fusions, osteotomies and non-unions of the clavicle, scapula, olecranon, humerus, radius, and ulna.
Versalock Upper Limb Plating System consists of plates and screws in a variety of designs and sizes that are commonly used in trauma and reconstructive surgery. The bone plates and screws are made from titanium alloy or pure titanium. The plates range in thickness from 1.4 to 3.5 mm, and the screws range in diameter from 2.0 to 3.5 mm. They are available on different sizes and shapes, according to the implantation site and the extension of the fracture. Versalock Upper Limb Plating System are for single use and the devices are provided non-sterile. They must be properly cleaned and sterilized before use, according to the recommendations provided in the Instructions for Use.
This document describes the Versalock Upper Limb Plating System, a medical device for internal bone fixation. However, it is a 510(k) Premarket Notification for a Class II medical device, specifically metallic bone fixation appliances and accessories. These types of devices generally rely on mechanical testing to demonstrate substantial equivalence rather than clinical studies involving human patients or AI performance metrics.
Therefore, many of the requested elements for a study proving acceptance criteria (such as sample sizes for test/training sets, expert consensus, MRMC studies, or standalone algorithm performance) are not applicable in this context. The acceptance criteria and "study" described herein are based on mechanical performance standards.
Here's an analysis of the provided information, focusing on what is available:
1. A table of acceptance criteria and the reported device performance
Acceptance Criteria (Standard) | Reported Device Performance |
---|---|
ASTM F382 (for plates) | Demonstrated equivalent to predicate devices based on submitted testing data. |
ASTM F543 (for screws) | Demonstrated equivalent to predicate devices based on submitted testing data. |
Explanation: The acceptance criteria for this device are defined by its ability to meet established mechanical testing standards (ASTM F382 for plates and ASTM F543 for screws) and demonstrate substantial equivalence to legally marketed predicate devices. The "reported device performance" is that it successfully met these criteria.
2. Sample size used for the test set and the data provenance
- Sample size: Not explicitly stated as a "test set" in the context of clinical or AI performance. For mechanical testing, the sample size would refer to the number of plates and screws tested per configuration. This information is typically detailed in the test reports, which are not included in this summary.
- Data provenance: Mechanical testing is conducted under controlled laboratory conditions, not on human data. The specific lab where the testing was performed is not mentioned, but the manufacturer is based in Brazil.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not Applicable. This device does not involve expert-established ground truth in the way an AI diagnostic device would. Its performance is assessed through objective mechanical properties.
4. Adjudication method for the test set
- Not Applicable. There is no "adjudication method" as understood in clinical studies with human observers. Mechanical testing results are compared against the accepted performance parameters of the ASTM standards and the predicate devices.
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 not an AI-assisted device, nor is it a diagnostic device that would involve human readers.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Not Applicable. This is a physical medical implant, not an algorithm.
7. The type of ground truth used
- The "ground truth" for this medical device is adherence to established mechanical performance standards (ASTM F382 and F543) and factual data demonstrating substantial equivalence in material, design, and performance to legally marketed predicate devices.
8. The sample size for the training set
- Not Applicable. This is a physical medical device, not an AI model.
9. How the ground truth for the training set was established
- Not Applicable.
In summary: The provided document is an FDA 510(k) clearance for a bone plating system. The "study" proving the device meets acceptance criteria is a series of mechanical tests conducted according to ASTM standards (F382 for plates, F543 for screws), which confirmed the device is mechanically equivalent to its predicate devices. The acceptance criteria are essentially defined by these standards and the equivalence to existing cleared devices. Information relevant to AI/clinical performance metrics (like expert reviews, reader studies, ground truth establishment for AI) is not relevant to this type of device submission.
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(56 days)
GMReis Ankle Plating System are intended to be used for internal bone fixation for bone fractures, fusions, osteotomies and non-unions in the ankle.
GMReis Ankle Plating System consists of plates and screws in a variety of designs and sizes that are commonly used in trauma and reconstructive surgery. The bone plates and screws are made from titanium alloy. The plates range in thickness from 1.8 to 3.6 mm, and the screws range in diameter from 2.7 to 3.5 mm. They are available on different sizes and shapes, according to the implantation site and the extension of the fracture. GMReis Ankle Plating System are for single use. The devices are provided non-sterile and must being properly cleaned and sterilized before use, according to the recommendations provided in the Instructions for Use.
This document, K242998, describes a 510(k) premarket notification for the "GMReis Ankle Plating System." This is a medical device, specifically bone plates and screws, and the submission aims to demonstrate its substantial equivalence to previously marketed predicate devices.
The request asks for information about the acceptance criteria and the study that proves the device meets them, specifically in the context of an AI/software-driven medical device. However, the provided document does NOT contain information about an AI/software component, nor does it detail acceptance criteria related to a diagnostic or analytical performance study typical of AI/software devices.
Instead, this document focuses on establishing substantial equivalence for a physical orthopedic implant through:
- Comparison of Technological Characteristics: Showing similarity in design, intended use, materials, manufacturing processes, and sterilization methods to predicate devices.
- Performance Data (Mechanical Testing): Demonstrating the physical performance of the plates and screws according to well-established ASTM standards for metallic bone fixation devices.
Therefore, I cannot provide the requested information regarding AI/software specific acceptance criteria, test set sample sizes, data provenance, expert ground truth, adjudication methods, MRMC studies, standalone AI performance, or training set details, as this information is not present in the provided document.
The "acceptance criteria" for this specific device (GMReis Ankle Plating System) are implicitly met by demonstrating that its mechanical performance is comparable to or better than the predicate devices, and that its materials and manufacturing processes are substantially equivalent.
Here's a breakdown of what can be extracted from the document, tailored to the spirit of your request but acknowledging the different nature of the device:
1. A table of acceptance criteria and the reported device performance
Acceptance Criteria (Implicit for a Bone Plate System) | Reported Device Performance (as stated in Section VII) |
---|---|
Mechanical Performance: | |
- Plate performance | Demonstrated through mechanical testing according to ASTM F382. |
- Screw performance | Demonstrated through mechanical testing according to ASTM F543. |
Material/Biocompatibility: | "substantially equivalent to the predicates with regard to materials and biocompatibility." |
Intended Use: | "same basic design and intended use" as predicate. |
Manufacturing Process: | "identical materials and identical manufacturing processes" as a previously cleared reference device (K182718). |
Sterilization Method: | "sterilized by the same methods" as predicate. |
Note: The document states "Based on submitted testing data, the subject device is equivalent to the predicate devices." The specific numerical or statistical results of these mechanical tests that demonstrate equivalency are not provided in this summary, but the assertion is that the acceptance criteria for mechanical performance (i.e., meeting or exceeding predicate performance as per ASTM standards) were met.
2. Sample sizes used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
- No information provided regarding sample sizes for human clinical data or diagnostic test sets, as this is a mechanical device primarily evaluated through engineering tests, not a diagnostic AI.
- Data Provenance: The mechanical testing data would typically be generated in a lab setting, presumably by the manufacturer (GM Dos Reis Industria e Comercio Ltda) from Brazil, as they are the submitter. The document does not specify the country of origin of the test data directly, but it would be expected to come from their internal or contracted testing facilities.
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 pertains to establishing ground truth for diagnostic accuracy, which is not relevant for this physical device. Mechanical testing results are based on objective physical measurements against standards, not expert interpretation.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
- Not applicable. No expert adjudication is described or required for mechanical testing of this nature.
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 bone plate system, not an AI diagnostic tool. No MRMC study was conducted.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Not applicable. This refers to AI algorithm performance.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not applicable directly. For mechanical testing, the "ground truth" is defined by the objective performance requirements outlined in the ASTM standards (e.g., specific load-bearing capacities, fatigue life). Compliance with these standards serves as the "truth" for the device's physical performance.
8. The sample size for the training set
- Not applicable. There is no "training set" as this is not an AI/machine learning device.
9. How the ground truth for the training set was established
- Not applicable. There is no "training set."
In summary, the provided FDA 510(k) clearance letter and summary for the GMReis Ankle Plating System clearly indicate that this is a physical implant device, and its safety and effectiveness (specifically substantial equivalence) are demonstrated through a comparison of physical characteristics and mechanical performance testing, not through AI/software validation studies.
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(287 days)
The Versalock Rib and Sternum Plates System is intended for use in the stabilization and fixation of fractures of the anterior chest wall including sternal fixation following sternal reconstructive surgical procedures, rib and sternum fractures, fusions and osteotomies.
The Versalock Rib and Sternum Plates System is indicated for the stabilization and rigid fixation of chest wall fractures, including sternal reconstruction processes, trauma and/or planned osteotomies. The physical principle is based on rigid fixation, where the screws have a specific thread profile in their head, which, when fixed, allows the surgeon to fix it with a variable angle of ±15° in the threaded hole of the plate. The system also allows fixation with non-threaded head screws when the surgeon so desires. The devices are presented in Titanium Alloy according to the standard ASTM F136 and Pure Titanium According to ASTM F67.
This document describes a 510(k) premarket notification for the "Versalock Rib and Sternum Plates System". This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than proving safety and effectiveness through clinical trials with specific acceptance criteria as you might see for a novel, high-risk device.
Therefore, the sections of your request related to "acceptance criteria," "study that proves the device meets the acceptance criteria," "sample sizes used for the test set," "number of experts used to establish ground truth," "adjudication method," "MRMC comparative effectiveness study," "standalone performance," "type of ground truth," "sample size for training set," and "how ground truth for the training set was established" are not directly applicable in the context of this 510(k) submission for a metallic bone fixation appliance.
Instead, the submission relies on demonstrating substantial equivalence through a comparison of technological characteristics and non-clinical performance testing to recognized consensus standards.
Here's a breakdown of the relevant information from the provided text, addressing your questions where possible within the context of a 510(k) submission for this type of device:
1. A table of acceptance criteria and the reported device performance
The document does not present a table of acceptance criteria and reported device performance in the manner typically seen for clinical diagnostic studies or novel performance claims. For a 510(k) for a metallic bone fixation device, "acceptance criteria" are generally met by demonstrating that the device's mechanical properties are comparable to or meet the requirements of established ASTM standards, which are considered sufficient to ensure safety and effectiveness for its intended use, similar to predicate devices.
The "reported device performance" is indicated by its successful testing against these standards, implying it met the performance expectations set forth by those standards.
Performance Characteristic | Standard Tested Against | Reported Outcome / "Acceptance" |
---|---|---|
Torsional Properties | ASTM F543 | Tested successfully |
Driving Torque | ASTM F543 | Tested successfully |
Axial Pullout Strength | ASTM F543 | Tested successfully |
Single Cycle Bending (Static) | ASTM F382 | Tested successfully |
Bending Fatigue Test | ASTM F382 | Tested successfully |
Lateral Distraction, Longitudinal and Transversal Shear | (No specific ASTM number listed, but implied as part of mechanical testing) | Tested successfully |
Pyrogenicity | USP | Device meets pyrogen limit specifications |
2. Sample size used for the test set and the data provenance
- Sample Size: The document does not specify the exact number of samples used for each mechanical test. This level of detail is typically found in the full test reports, not in the 510(k) summary. However, recognized consensus standards like ASTM F543 and F382 usually dictate the minimum number of samples required for robust testing.
- Data Provenance: The testing was "non-clinical" and performed against recognized consensus standards (ASTM F543, ASTM F382, USP ). This implies laboratory-based mechanical and biological (pyrogen) testing. The country of origin of the data is not explicitly stated, but the manufacturer is based in Brazil, suggesting the testing could have occurred there or by a certified lab elsewhere. The data is prospective in the sense that these tests were conducted specifically for this submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
N/A. For mechanical and biological performance testing of a bone fixation device, "experts" in the sense of establishing clinical ground truth (like radiologists reading images) are not applicable. The "ground truth" for this device is its physical and material properties, assessed by engineering and laboratory methods against established standards.
4. Adjudication method for the test set
N/A. Adjudication methods (like 2+1 reader consensus) are relevant for clinical studies, particularly in image interpretation or diagnostic pathways. This submission relies on objective mechanical and biological test results.
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. This is a medical device for physical fixation, not an AI/software device or a diagnostic tool requiring human reader interpretation. No MRMC study was conducted or is relevant for this device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
N/A. This device is not an algorithm or AI. It is a physical implant.
7. The type of ground truth used
The "ground truth" for this device, in the context of its 510(k) submission, is established through:
* Mechanical properties: Measured values obtained from testing according to ASTM F543 and ASTM F382, which serve as objective standards for bone fixation devices.
* Material composition: Conformance to ASTM F136 (Titanium Alloy) and ASTM F67 (Pure Titanium).
* Biocompatibility/Sterility related: Meeting pyrogen limit specifications per USP .
* Substantial Equivalence: Comparison to the design, materials, and intended use of legally marketed predicate devices (K161590, K161896).
8. The sample size for the training set
N/A. This is not an AI/machine learning device, so there is no training set in that context. If "training set" is meant as in "samples used for development and iterative testing," that information is not provided in the summary.
9. How the ground truth for the training set was established
N/A. Not applicable for this type of device and submission.
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(118 days)
Cut Screw - Percutaneous Compression Screw are single use devices indicated for fixing and stabilizing the bones of the mid foot, metatarsal and phalanges of the foot using an appropriate relation bone-screw size.
The Cut Screw - Percutaneous Compression Screw for bone synthesis, with a hole in the center in order to allow the passage of the guide wire, thus facilitating its placement, as the surgeon is able to verify the positioning of the screw through the radiological image of the guide wire before its placement. In addition, the Cut Screw -Percutaneous Compression Screw, provides anatomical reduction, stable fixation, and preservation of blood supply by using a percutaneous incision. The screws have a hexagonal connection for a wrench. They are found in a variety of diameters to meet the range of anatomies of the patients, are presented in Titanium Alloy according to the standard ASTM F136, it could be provided in sterile condition sterilized by Ethylene Oxide or non-sterile condition to end user and must be cleaned, and steam sterilized before use.
The provided document is a 510(k) Premarket Notification for a medical device called "Cut Screw - Percutaneous Compression Screw." This document focuses on demonstrating substantial equivalence to an already legally marketed device (predicate device) rather than clinical performance (e.g., diagnostic accuracy of an AI/ML algorithm). Therefore, the information requested in your prompt, which pertains to the acceptance criteria and study design for proving the performance of a device, particularly for AI/ML-based medical devices, is not present in this document.
Specifically, the document states:
- "No clinical data were included in this submission." (page 5)
- The performance data provided is limited to non-clinical mechanical testing (Torsional Properties, Driving Torque, Axial Pullout Strength per ASTM F543) to demonstrate safety and efficacy in terms of mechanical properties. (page 5 & 6)
Therefore, I cannot provide answers to the questions regarding acceptance criteria, study types (MRMC, standalone), ground truth, sample sizes for test/training sets, or expert qualifications as these are not relevant to this type of device submission as described in the provided text.
The document's purpose is to show similarity in design, materials, and mechanical performance to an already approved device, rather than proving a new diagnostic or therapeutic capability through clinical studies.
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(258 days)
The Versalock Periprosthetic Femur Plates is indicated for temporary internal fixation and stabilization of fractures and osteotomies of the femur, including:
- · Periprosthetic fractures
- Comminuted fractures
- Supracondylar fractures
- Trochanteric fractures
- · Fractures in normal and osteopenic bone
- Non-unions and Malunions.
The purpose of this submission is to obtain marketing clearance for the Versalock Periprosthetic Femur Plates System which is composed of plates, screws and, a cerclage cable and related device.
The subject devices are designed for the treatment of femur fractures, particularly, periprosthetic femur fractures. The plates are available in the following design-types to be used according to the fracture location: Proximal and Distal Femur Periprosthetic Plates, Trochanteric Periprosthetic Plates and Condylar Femur Plates.
The plates are for use with the subject device screws to fix them to the bone. The following compatible screws are available for this purpose: Cortical Screws, Versalock Variable Angle Locking Screws, Versalock Variable Angle Screws, Versalock Variable Angle Cannulated Screws and Versalock Variable Angle Periprosthetic Screw. The Trochanteric Plate Fastening Screw is to connect one plate to another when a Trochanteric Periprosthetic Plates is used. The Versalock Spacer Screw is threaded into the plate hole prior to plate insertion to act as a spacer providing no contact between the plate and the bone surface.
The Gama Cable is a cerclage cable indicated to provide fixation and/or stabilization of the bone when it is not possible the usage of any screw. The Gama Cable related devices are the Gama Cable Lock and the Versalock Connector Screw. During the installation of the Gama Cable Lock is crimped to lock the movement of the cable, maintaining the tensioning applied while the Versalock Connector Screw , which holds the cable to the plate and set the proper cable routing position. The Gama Cable and related devices are used in conjunction with the Proximal or Distal Femur Periprosthetic Plates, or Condylar Femur Plates
The subject devices are made of made of titanium alloy (ASTM F136) with exception of the Gama Cable Lock which it is made of commercially pure titanium (ASTM F67). All the subject devices are coloredanodized.
The devices must only be used by qualified surgeons mastering the surgical technique, having been trained and qualified in orthopedic surgeries.
The provided document is a 510(k) summary for the Versalock Periprosthetic Femur Plates System - GMReis. This document outlines the regulatory submission for a medical device and, as such, does not contain information about a study that proves the device meets specific acceptance criteria in terms of clinical performance or diagnostic accuracy. Instead, it focuses on demonstrating substantial equivalence to a predicate device through non-clinical performance testing.
Therefore, many of the requested sections related to clinical studies, sample sizes for test and training sets, expert ground truth adjudication, MRMC studies, or standalone algorithm performance will not be available in this document.
Here's a breakdown of the information that can be extracted or inferred from the provided text:
1. Table of Acceptance Criteria and Reported Device Performance:
The document doesn't provide a table of explicit acceptance criteria with specific numerical targets. Instead, it states that performance was demonstrated through mechanical testing according to established ASTM standards. The "performance" in this context refers to the device's mechanical integrity and functionality, rather than a clinical outcome.
Acceptance Criteria (Standard Adherence) | Reported Device Performance (Demonstrated Adherence) |
---|---|
Adherence to ASTM F382 for plates (static and dynamic testing) | Performance of subject device plates was demonstrated through static and dynamic testing according to ASTM F382. |
Adherence to ASTM F543 for screws (mechanical testing) | Performance of subject screws was demonstrated through mechanical testing according to ASTM F543. |
Adherence to ASTM F2180 for cerclage cable (mechanical testing) | Performance of the cerclage cable was demonstrated through mechanical testing according to ASTM F2180. |
System construct testing for cerclage cable | Performance of the cerclage cable was demonstrated through system construct testing. |
Biocompatibility established via risk assessment following ISO 10993-1 | Biocompatibility was established through a risk assessment following ISO 10993-1. |
Equivalence in indications for use, design principles, materials, physical dimensions, and sterilization method to predicate device | The subject and predicate devices have equivalent intended use and equivalent technological characteristics. The subject and predicate devices are all manufactured from identical or equivalent materials and share equivalent design characteristics. The subject and predicate devices encompass equivalent physical dimensions and are to be sterilized by identical or equivalent method. |
No new issues of safety or efficacy raised by technological differences | Any difference in the technological characteristics do not raise new issues of safety or efficacy. |
2. Sample size used for the test set and the data provenance:
- Sample Size: Not applicable. This document describes mechanical testing of physical device components, not a study involving patient data or a "test set" in the context of AI/diagnostic device performance. The sample sizes would refer to the number of plates, screws, and cables tested in the lab. This specific number is not provided, though it would typically be defined by the ASTM standards.
- Data Provenance: Not applicable. The data comes from internal mechanical testing, not patient data from a specific country or collected retrospectively/prospectively.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. Ground truth as typically defined for diagnostic AI/clinical studies (e.g., expert consensus on images, pathology results) is not relevant to this type of device submission. The "ground truth" here is the adherence to mechanical engineering standards, which is determined by test procedures and measurement against those standards.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable for the reasons stated above.
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:
- No. This is not a diagnostic AI device, and therefore, an MRMC study is not relevant or mentioned.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- No. This is a physical medical implant device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- For the non-clinical performance (mechanical testing), the "ground truth" is adherence to established engineering standards (ASTM F382, ASTM F543, ASTM F2180) and a risk assessment based on biocompatibility standards (ISO 10993-1).
- For the substantial equivalence claim, the "ground truth" is the characteristics of the predicate device, which the subject device is compared against.
8. The sample size for the training set:
- Not applicable. There is no training set mentioned as this is not an AI/machine learning device.
9. How the ground truth for the training set was established:
- Not applicable. There is no training set.
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(262 days)
The EXPERT - Joint Fixation System is intended as an adjunct in fracture repair involving metaphyseal and periarticular bone fragments where screws are not indicated, and as an adjunct in external and intramedullary fixation systems involving plates and nails, with fracture braces and casting.
The Mini EXPERT, EXPERT Knotless and EXPERT Knotless Dual are intended to provide fixation during the healing process following:
Mini EXPERT
When used for fixation of bone, the Mini EXPERT is intended as fixation posts, distribution bridges, or for distributing suture tension over areas of ligament or tendon repair, such as:
-
Syndesmotic trauma, such as fixation of dorsal distal radioulnar ligament (DRUL) disruptions;
-
Tarsometatarsal (TMT) injury, such as fixation of foot soft tissue separations due to a Lisfranc injury (Midfoot Reconstruction); and
-
Carpal Metacarpal (CMC) joint arthroplasty as an adjunct in the healing process of the ligament at the base of the thumb metacarpal by providing stabilization between the first and second metacarpal when the trapezium has been excised due to osteoarthritis.
EXPERT Knotless and EXPERT Knotless Dual
Syndesmotic trauma, such as fixation of syndesmosis disruptions) in connection with Weber B and C ankle fractures.
The EXPERT – Joint Fixation System is available in three models. Each model is composed of different medical devices (i.e. plates, surgical suture) assembled together for the purpose of use as a set. Each set is composed of plates from different sizes and shapes made of Titanium Alloy (ASTM F136) associated with non-absorbable surgical sutures and/or surgical meshes made of an Ultra-High Molecular Weight Polyethylene (UHMWPE).
The metallic components are manufactured by GM dos Reis Indústria e Comércio Ltda and the nonabsorbable Surgical Sutures and Surgical Suture Meshes are purchased in bulk from River Point Medical (K100006).
Each EXPERT model comes with a transient use guidewire accessory in the same package. The guidewire is made of Stainless Steel (ASTM F138) to aid in the EXPERT - Joint Fixation System placement.
In order to promote a correct placement of EXPERT – Joint Fixation System, GMReis has also available a range of instruments (class I exempt) to serve the surgeon such as drill bits, drill guides, plier, among others. GMReis recommends the use of these instruments in order to ensure the compatibility with the subject devices and promote the success of the procedure.
This document describes the EXPERT - Joint Fixation System and its substantial equivalence to predicate devices, focusing on the mechanical performance of the device rather than AI/software performance. Therefore, many of the typical acceptance criteria and study design elements found in AI/ML medical device submissions (such as ground truth establishment involving expert consensus, MRMC studies, or standalone algorithm performance) are not applicable here.
The "study" in this context refers to mechanical testing that demonstrates the device's physical performance characteristics are comparable to legally marketed predicate devices.
Here's a breakdown based on the provided document:
Acceptance Criteria and Device Performance
The acceptance criteria are implicitly defined by demonstrating substantial equivalence to existing predicate devices through mechanical testing. The document states:
- "The performance of the subject devices compared with the predicate devices are demonstrated through mechanical testing."
- "The documentation submitted in this premarket notification demonstrates that the subject devices have comparable features and performance and, therefore, are substantially equivalent to the identified predicate devices."
Since this is a 510(k) submission for a physical medical device (joint fixation system) and not an AI/ML diagnostic or prognostic tool, the "performance" is related to its physical and functional characteristics (e.g., strength, durability, fixation capability) as compared to the predicates. The document does not explicitly list quantitative acceptance criteria values or detailed reported device performance data in a table format. Instead, it relies on the conclusion that mechanical tests confirm comparability.
Table of Acceptance Criteria and Reported Device Performance (Inferred from 510(k) Context):
Acceptance Criteria Category (Implicit) | Specific Criteria (Inferred) | Reported Device Performance (Inferred) |
---|---|---|
Mechanical Performance | Comparable mechanical properties (e.g., stiffness, strength, durability, fatigue resistance) to predicate devices for intended use. | Mechanically tested to demonstrate comparable features and performance to predicate devices (K090107, K061925, K043248, K111032). The submission concludes that "Any differnce in the technological characteristics do not raise new issues of safety or efficacy." Specific numerical values for the tests are not provided in this summary document, but are implied to have been submitted to the FDA and met the internal acceptance parameters for substantial equivalence. |
Material Biocompatibility | Biocompatibility in accordance with ISO 10993-1 and AAMI/ANSI ST72. (Cytotoxicity, Sensitization, Intracutaneous Reactivity, Acute Systemic Toxicity, Material-mediated Pyrogenicity Testing, Pyrogenicity monitoring). | Biocompatibility confirmed for Titanium Alloy (referenced K180626, K182718), UHMWPE surgical sutures (referenced K100006), and Stainless Steel guidewire (specific test reports cited). |
Sterilization & Shelf Life | Sterilization validity per ISO 11135 and a shelf life of 3 years. | Ethylene oxide sterilization validation performed according to ISO 11135. Device provided sterile with a 3-year shelf life. |
Study Information (Mechanical Testing for Substantial Equivalence)
-
Sample Size Used for the Test Set and Data Provenance:
- Sample Size: Not specified in the provided summary. For mechanical testing of medical devices, sample sizes are typically determined by statistical rationale to ensure robustness and representativeness of the device's performance.
- Data Provenance: The testing was conducted as part of the submission by GM dos Reis Indústria e Comércio Ltda, a Brazilian company. The data would be prospective, as it was generated specifically for this 510(k) submission.
-
Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
- Not Applicable. This is a submission for a physical joint fixation system, not an AI/ML device requiring human expert annotation of medical images or clinical outcomes for ground truth. Ground truth for mechanical performance is established through standardized engineering tests and material science evaluations.
-
Adjudication Method for the Test Set:
- Not Applicable. See point 2.
-
Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- Not Applicable. This type of study is relevant for AI/ML devices that assist human readers (e.g., radiologists) in diagnostic tasks. The EXPERT - Joint Fixation System is a physical implant.
-
Standalone (Algorithm Only) Performance:
- Not Applicable. No algorithms or software are involved in the primary function or assessment of this physical device.
-
Type of Ground Truth Used:
- Engineering Specifications and Standardized Test Methods: For mechanical performance, ground truth is established by universally accepted engineering principles, material standards (e.g., ASTM, ISO), and validated test methods (e.g., fatigue testing, tensile strength). For biocompatibility, it's established by adherence to ISO 10993 series standards and AAMI/ANSI ST72.
-
Sample Size for the Training Set:
- Not Applicable. There is no "training set" in the context of mechanical testing for a physical medical device. Device design and manufacturing processes are refined through engineering iterations.
-
How the Ground Truth for the Training Set Was Established:
- Not Applicable. See point 7.
Summary of Information NOT Applicable to this Submission:
Due to the nature of the device (a physical joint fixation system) and the regulatory submission (510(k) based on substantial equivalence through mechanical testing), the following elements, commonly associated with AI/ML device evaluations, are not found in the provided document:
- Detailed quantitative performance metrics in a readily available table.
- Specific sample sizes for a "test set" in the context of clinical/image data.
- Data provenance involving patient demographics or retrospective/prospective medical data collection.
- Number/qualifications of experts for ground truth establishment.
- Adjudication methods.
- MRMC studies.
- Standalone algorithm performance.
- Training set information.
The document unequivocally states: "No clinical data were included in this submission." This further confirms that the evaluation focused on physical and mechanical properties, not clinical outcomes or human performance with AI assistance.
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