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510(k) Data Aggregation
(156 days)
The Memometal Technologies' SubFix Arthroereisis Implant is intended to treat the hyperpronated foot and stabilize the subtalar joint. It is intended to block forward, downward and medial displacement of the talus, thus allowing subtalar joint motion but blocking excessive pronation and the resulting sequela.
The SubFix Arthroereisis Implants are intended for single use only.
The Memometal Implant is a one-piece device made of medical grade Titanium Alloy, Ti6A14V. The implant is available in 5 sizes ranging from 6.5 mm to 11.5 in diameter. No new materials or processes are used in the development of this implant.
The provided text is a 510(k) summary for the SubFix Arthroereisis Implant. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving performance against specific acceptance criteria through clinical studies in the same way a PMA (Pre-Market Approval) submission would.
Therefore, the document does not contain the information requested regarding acceptance criteria and a study proving the device meets them, as it relies on a different regulatory pathway.
Specifically, it states: "An engineering analysis and a material comparison to various predicate devices were used to help demonstrate equivalence." This indicates that the primary "study" for this 510(k) was a comparison to existing devices, not a new performance study with specific acceptance criteria.
Let me address each point based on the information available and not available in the provided text:
1. A table of acceptance criteria and the reported device performance
- Not available. The document does not define specific acceptance criteria or report performance data against such criteria in the context of a new efficacy study. The document focuses on demonstrating substantial equivalence to predicate devices through design characteristics, intended use, engineering analysis, and material comparison.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Not applicable / Not available. Since no performance study demonstrating efficacy against acceptance criteria is described, there is no "test set" in that context. The "test" for this 510(k) was an engineering and material comparison to existing predicate devices.
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 / Not available. No ground truth establishment by experts is mentioned, as the submission relies on comparison to predicate devices, not on a new clinical study requiring ground truth.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable / Not available. No adjudication method is mentioned as there's no clinical test set requiring it.
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 a medical implant, not an AI-assisted diagnostic tool. An MRMC study is not relevant here.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- No. This is a medical implant, not a standalone algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not applicable / Not available. No ground truth is established for a new clinical study. The "ground truth" for this 510(k) is implicitly the established safety and effectiveness of the existing predicate devices.
8. The sample size for the training set
- Not applicable / Not available. This is a medical implant, not a machine learning model, so there is no training set.
9. How the ground truth for the training set was established
- Not applicable / Not available. As above, no training set for a machine learning model is involved.
Summary of the "Study" provided in the document:
The submission for the SubFix Arthroereisis Implant is a 510(k) Premarket Notification based on substantial equivalence to legally marketed predicate devices. The "performance data" section states:
- "An engineering analysis and a material comparison to various predicate devices were used to help demonstrate equivalence."
This indicates the study was a technical comparison, not a clinical trial with specific performance metrics and acceptance criteria for the new device's efficacy. The relevant aspect explored was the similarity in design, materials, and intended use to existing, approved devices.
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(85 days)
The Futura Biomedical Subtalar Peg Implant is intended to treat hyperpronated foot and stabilize the subtalar joint. It is intended to block forward, downward and medial displacement of the talus, thus allowing normal subtalar joint motion but blocking excessive pronation and the resulting sequela. Examples include: Flat foot treatment in children and adolescents Congenital flat foot Unsuccessful long term orthopaedic treatment (shoes, insoles ... ) Tarsal coalitions Painful flat foot Supple deformity in posterior tibial tendon dysfunction Paralytic flat foot Subtalar instability This device is intended to be fixed with bone cement.
The Futura Biomedical Implant is a one-piece device made of UHMWPE or Cobalt Chromium with titanium plasma spray on the stem, intended to be implanted into the calcaneus of the foot. The implant is designed in 13 sizes and two configurations. The implant which is used in the treatment of excessive motion of the talus relative to the calcaneus acts as a spacer for the joint, maintaining the joint space, allowing for range of motion, but limiting excessive pronation.
This document is a 510(k) Summary for the Futura Biomedical Subtalar Peg Implant, comparing it to a predicate device, the Wright Medical STA-Peg implant. The purpose of this document is to demonstrate "substantial equivalence" to a legally marketed device, not to present a study proving the device meets specific acceptance criteria in the way an AI/ML device submission would.
Therefore, the requested information regarding acceptance criteria, study details, ground truth establishment, expert involvement, and sample sizes for training/test sets is not applicable in this context. This document pertains to a traditional medical device (an implant), not a software as a medical device (SaMD) or an AI/ML-driven device.
However, I can extract the comparison between the new device and the predicate device, which serves a similar purpose of demonstrating safety and effectiveness based on existing, accepted technology.
1. Table of Acceptance Criteria and Reported Device Performance:
For a traditional medical device like an implant, acceptance criteria are typically met through demonstrating equivalence in design, materials, and intended use as compared to a legally marketed predicate device. The "performance" in this context refers to its ability to function as intended based on these equivalences.
Item | Acceptance Criteria (Implied by Predicate Device) | Futura Biomedical Subtalar Peg Implant Performance (as reported) |
---|---|---|
Product Name | STA-Peg Implant (Predicate) | Subtalar Peg Implant |
Use | Single use | Single use |
Fixation | Stem in bone | Stem in bone |
Constraint | Non constrained | Non constrained |
Material | UHMWPE | UHMWPE or CoCr/CpTi |
Sizes | 5 sizes | 5 sizes, two configurations (13 sizes) |
Indications for use | The STA-Peg implant is intended to treat hyperpronated foot and stabilize the subtalar joint. It is intended to block forward, downward and medial displacement of the talus, thus allowing normal subtalar joint motion but blocking excessive pronation and the resulting sequela. Examples include: Flat foot treatment in children and adolescents, Congenital flat foot, Unsuccessful long term orthopaedic treatment (shoes, insoles...), Tarsal coalitions, Painful flat foot, Supple deformity in posterior tibial tendon dysfunction, Paralytic flat foot, Subtalar instability. (Implied: Device is intended to be fixed with bone cement). | The Futura Biomedical Subtalar Peg Implant is intended to treat hyperpronated foot and stabilize the subtalar joint. It is intended to block forward, downward and medial displacement of the talus, thus allowing normal subtalar joint motion but blocking excessive pronation and the resulting sequela. Examples include: Flat foot treatment in children and adolescents, Congenital flat foot, Unsuccessful long term orthopaedic treatment (shoes, insoles...), Tarsal coalitions, Painful flat foot, Supple deformity in posterior tibial tendon dysfunction, Paralytic flat foot, Subtalar instability. This device is intended to be fixed with bone cement. |
Summary of How the Device Meets "Acceptance Criteria" (Substantial Equivalence):
The study (the 510(k) submission itself) demonstrates that the Futura Biomedical Subtalar Peg Implant is substantially equivalent to the legally marketed predicate device (Wright Medical STA-Peg implant) based on the following:
- Similarities in Design Characteristics and Intended Use: Both devices are for single use, intended for surgical implantation, designed to prevent excessive pronation while allowing normal subtalar joint motion, and are made of comparably sized, industry-standard materials.
- Identical Indications for Use: The stated indications for both devices are precisely the same, covering various conditions associated with hyperpronated foot and subtalar joint instability.
- Similar Device Mechanics: Both implants function as spacers to maintain joint space and limit excessive pronation.
- Material Equivalence: While the new device offers an additional material option (CoCr/CpTi), UHMWPE is common to both, and the provided materials are understood to be suitable for this application.
- Fixation Method: Both devices are intended for stem-in-bone fixation, with the Futura device explicitly mentioning fixation with bone cement, which is a common and accepted method.
2. Sample Size Used for the Test Set and Data Provenance:
Not applicable. This is a submission for a traditional implant, not a data-driven AI/ML device. There is no "test set" in the context of an algorithm's performance. The "test" is the comparison to the predicate device.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:
Not applicable. Ground truth, in the context of expert consensus for AI/ML devices, is not a concept applied to the substantial equivalence determination of a traditional implant. The "ground truth" here is the established safety and effectiveness of the legally marketed predicate device.
4. Adjudication Method (e.g., 2+1, 3+1, none) for the Test Set:
Not applicable. This concept does not apply to this type of device submission.
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-driven device.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done:
Not applicable. This is not an AI-driven device.
7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc):
The "ground truth" in this context is the safety and effectiveness profile of the legally marketed predicate device (Wright Medical STA-Peg implant), which has already established its performance in clinical use and met regulatory requirements. The new device is deemed acceptable because it is substantially equivalent to this established device.
8. The Sample Size for the Training Set:
Not applicable. There is no "training set" for this type of device.
9. How the Ground Truth for the Training Set Was Established:
Not applicable. There is no "training set" for this type of device.
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