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510(k) Data Aggregation

    K Number
    K241314
    Manufacturer
    Date Cleared
    2024-08-16

    (98 days)

    Product Code
    Regulation Number
    872.4760
    Panel
    Dental
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    KLS Mini Osteosynthesis System (K943347): The KLS Mini Osteosynthesis System is indicated for 1) Fractures, 3) Reconstruction procedures of the craniomaxillofial skeletal system.
    KLS Chin Plate System (K943348): The KLS Chin Plate System is indicated for 1) Fractures, 3) Reconstruction procedures of the craniomaxillofacial skeletal system.
    KLS-Martin Micro Osteosynthesis System (1.0MM) (K944561): The KLS-Martin Micro Osteosynthesis System (1.0MM) is used in oral-maxillo-cranio-facial surgery to stabilize fractures. The bone segments are attached to the plate with screws to prevent movement of the segments.
    KLS-Martin Micro Osteosynthesis System (1.5MM) (K944565): The KLS-Martin Micro Osteosynthesis System (1.5MM) is used in oral-maxillo-cranio-facial surgery to stabilize fractures. The bone segments are attached to the plate with screws to prevent movement of the segments.
    KLS Martin Centre-Drive Drill-Free Screw (K971297): The KLS Martin Centre-Drive Drill-Free Screws are in rigid internal fixation of the oral-maxillo-cranio-facial bones. The bone screws are used to anchor plates which are contoured to fit the bone fragments. The addition of the self drilling feature is the only difference between the submitted device and the predicate device referenced.
    KLS-Martin Temporary Condylar Implant (K990667): The KLS-Martin Temporary Condylar Implant is only intended for temporary reconstruction of the mandibular condyle in patients who have undergone resective procedures to remove malignant or benign the removal of the mandibular condyle. This device is not for permanent implantation, for patients with TMF or treatment of temporomandibular joint disease (TMD).
    KLS-Martin Mandibular/Reconstruction System II (K032442): The KLS-Martin Mandibular/Reconstruction System II is intended for use in the stabilization of mandibular fractures and mandibular reconstruction.
    KLS-Martin Ortho Anchorage System (K033483): The KLS-Martin Ortho Anchorage System is intended to be surgically placed in the mouth for use an an anchor for orthodontic procedures.
    KLS-Martin Ortho Anchorage System (Plates) (K040891): The KLS-Martin Ortho Anchorage System (Plates) are implants intended to be surgically placed in the mouth for use as an anchor for orthodontic procedures in patients.
    KLS Martin Rigid Fixation - Sterile (K060177): The KLS Martin Rigid Fixation - Sterile is in sterile packaging, osteosynthesis products with the following indications for use:
    K051236: The RESORB-X® SF Sonotrode is only intended for use for insertion of the RESORB-X® SF pins.
    K032442: The KLS Martin Mandibular/Reconstruction System II is intended for use in the stabilization of mandibular fractures and mandibular reconstruction.
    K971297: The KLS Martin Centre-Drive Drill-Free screws are in rigid internal fixation of the oral-maxillo-cranio-facial bones. The bone screws are used to anchor plates which are contoured to fit the bony surface and stabilize the bone fragments. The addition of the self drilling feature is the only difference between the predicate device reference
    K944565: The KLS-Martin Micro Osteosynthesis System is used in oral-maxillo-cranio-facial surgery to stabilize fractured bone segments. The bone segments are attached to the plate with screws to prevent movement of the segments.
    K944561: The KLS-Martin Micro Osteosynthesis System is used in oral-maxillo-cranio-facial surgery to stabilize fractured bone segments. The bone segments are attached to the plate with screws to prevent movement of the segments.
    KLS Martin Drill-Free MMF Screw (K042573): The KLS Martin Drill-Free MMF Screws is intended for use in maxilonandibular fixation of fractures of the maxilla, mandible, or both.
    Drill Free MMF Screw (K083432): The Drill Free MMF Screw is intended for use in maxillomandibular fixation of fractures of the maxilla, mandible, or both.
    KLS Martin L1 MMF System (K173320): The KLS Martin L1 MMF System is intended for temporary stabilization of maxillary fractures. It is designed to maintain proper occlusion during intraoperative bone healing (app. 6-8 weeks). It is indicated for the temporary treatment of maxillomandibular fixation (MMF) in adults or adolescents who have permanent teeth present (ages 12 and older).

    Device Description

    KLS Mini Osteosynthesis System (K943347): The KLS Mini Osteosynthesis System consists of titanium non-locking plates ranging in thickness from 0.6mm - 2.5mm and titanium screws ranging in diameter from 1.5mm - 2.3mm.
    KLS Chin Plate System (K943348): The KLS Chin Plate System consists of titanium plates ranging in thickness of 0.6mm and titanium screws ranging in diameter from 1.5mm - 2.3mm.
    KLS-Martin Micro Osteosynthesis System (1.0mm) (K944561): The KLS-Martin Micro Osteosynthesis System is designed to aid in the alignment and stabilization of the skeletal system after a facial fracture or surgery. The bone plates, bone plates, bone screws and accessories of various shapes and sizes for use in oral-maxillo-cranio-facial surgery. The bone plates are manufactured from CP Titanium and range in thickness from 0.3mm - 0.6mm. The bone screws are manufactured from Titanium Alloy and range in diameter from 1.0mm - 1.2mm.
    KLS-Martin Micro Osteosynthesis System (1.5mm) (K944565): The KLS-Martin Micro Osteosynthesis System is designed to aid in the alignment and stabilization of the skeletal system after a facial fracture or surgery. The bone plates and screws of various shapes and sizes for use in oralmaxillo-cranio-facial surgery. The bone plates are manufactured from CP Titanium and range in thickness from 0.3mm - 0.6mm. The bone screws are manufactured from Titanium Alloy and range in diameter from 1.5mm - 1.8mm.
    KLS Martin Centre-Drive Drill-Free Screw (K971297): The KLS Martin Centre-Drive Drill-Free Screws are designed to eliminate the need for pre-drilled pilot holes. They are self-tapping with one step insertion. They are intended for use in rigid internal fixation of the oral-maxillo-cranio-facial bones. The bone screws are used to anchor plates where are contoured to fit the bone fragments. The bone fragments. The bone screws are manufactured from Titanium Alloy and range in diameter from 1.0mm - 2.0mm.
    KLS-Martin Temporary Condylar Implant (K990667): The KLS-Martin Temporary Condylar Implant is a solid condylar head which attaches with fastening screws to a KLS-Martin Fracture/ Reconstruction Plate. The implant is available for left and right placement. The KLS-Martin Temporary Condy intended for temporary reconstruction of the mandibular condyle in patients who have undergone resective procedures to benign tumors requiring the removal of the mandibular condyle. This device is not for permanent implantation, for patients with TMJ or traumatic injuries, or for treatment of temporomandibular joint disease (TMD).
    KLS-Martin Mandibular/Reconstruction System II (K032442): The KLS-Martin Mandibular/Reconstruction System II includes several different designs of titanium plates and screws intended for use in the stabilization and fixation of mandibular fractures and reconstruction. The plates are manufactured from either CP Titanium or Titanium Alloy and range in thickness from 1.0mm - 3.0mm. The screws are manufactured from either CP Titanium Alloy and range in diameter from 2.0mm - 3.2mm.
    KLS-Martin Ortho Anchorage System (K033483): The KLS-Martin Ortho Anchorage System consists of a titanium screw designed to aid in dental movement by providing a rigid skeletal fixation point. The screw is intended to be surgically placed in the mouth for orthodontic procedures. The screws are manufactured from either CP Titanium or Titanium Alloy.
    KLS-Martin Ortho Anchorage System (Plates) (K040891): The KLS-Martin Ortho Anchorage System (Plates) consists of titanium non-locking plates to aid in dental movement by providing a rigid skeletal fixation point. The plates are manufactured from either CP Titanium Alloy and are fixated with titanium screws and are utilized as an anchor for orthodontic procedures in the palatal, maxilla or mandible region.
    KLS-Martin Drill-Free MMF Screw (K042573): The KLS-Martin Drill-Free MMF Screw provides temporary occlusal and fracture stabilization. These screws may be applied prior to or after exposure of the fracture. The KLS-Martin Drill-Free MMF Screw is in maxillomandibular fixation to provide stabilization of fractures of the maxilla, or both. The screws are manufactured from either CP Titanium Alloy and are provided in 2.0mm diameter with lengths ranging from 8mm - 12mm.
    KLS Martin Rigid Fixation - Sterile (K060177): The KLS Martin Rigid Fixation - Sterile includes titanium plates of various shapes and thickness, titanium screws of various length and diameter, stainless steel twist drills of various length and stainless steel sonotrode tips that are provided in sterile packaging. The KLS Martin Rigid Fixation - Sterile is intended to provide KLS Martin's previously cleared osteosynthesis products in sterile packaging.
    Drill Free MMF Screw (K083432): The Drill Free MMF Screw provides temporary occlusal and fracture stabilization. These screws may be applied prior to or after exposure of the fracture. The Drill Free MMF Screw is in maxillomandibular fixation to provide stabilization of fractures of the maxilla, mandible, or both. The screws are manufactured from Stainless Steel and are provided in 2.0mm diameter with lengths ranging from 8mm - 12mm.
    KLS Martin L1 MMF System (K173320): The KLS Martin L1 MMF System is a bone-borne maxillomandibular fixation (MMF) system consisting of metalic archbars with sliding locking plates that attach to the dental arches with screws. The system is intended to provide temporary stabilization of mandibular and maxillary fractures as well as maintain properative bone fixation and postoperative bone healing (app. 6-8 weeks). The patient is brought into occlusion by wiring around the archbar wire hooks. The L1 MMF system plates are manufactured from CP Titanium (ASTM F67), are available in either a 7-hole siding plate configuration with two different lengths, and are 0.5mm in plate thickness. The L1 MMF system sliding locking plates are fixated with either 2.0 x 6 mm selfdrilling locking screws manufactured from Ti-6Al-4V (ASTM F136). Implants are available both sterile. The system also includes the necessary instruments to facilitate placement of the implants.

    AI/ML Overview

    The document describes the KLS Martin Oral-Max Implants - MR Conditional, a bundled submission of various osteosynthesis systems and screws intended for use in craniomaxillofacial surgery. The purpose of this submission is to support the conditional safety and labeling modification of these devices in the magnetic resonance (MR) environment.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them:

    1. A table of acceptance criteria and the reported device performance

    The acceptance criteria are implied by the non-clinical tests conducted to support MR Conditional safety, aligning with relevant ASTM standards and FDA guidance. The reported device performance is that the devices can be safely scanned under specified conditions.

    Acceptance Criteria (from ASTM/FDA Guidance)Reported Device Performance (Summary from Submission)
    Magnetically induced displacement force within acceptable limits (ASTM F2052-21)Not explicitly quantified but implied as acceptable for MR Conditional labeling.
    Magnetically induced torque within acceptable limits (ASTM F2213-17)Not explicitly quantified but implied as acceptable for MR Conditional labeling.
    Image artifacts within acceptable limits (ASTM F2119-07, R2013)Not explicitly quantified but implied as acceptable for MR Conditional labeling.
    RF-induced heating (ASTM F2182-19e2) resulting in a temperature rise below 6 ℃Achieved under specified scanning conditions: 1.5 T/64 MHz and 3 T/128 MHz at a whole-body averaged specific absorption rate (wbSAR) of 2 W/kg or head SAR of 3.2 W/kg for an hour-long scanning session.

    2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)

    The testing involved computational modeling and simulation (CM&S). The "test set" in this context refers to the simulated scenarios and device configurations.

    • Sample Size for Test Set: "the entire portfolio of KLS Martin maxillofacial implants" was simulated. This implies that all devices grouped under "KLS Martin Oral-Max Implants - MR Conditional" were included in the simulations. The document also mentions "various in-vivo device positions and landmarks," "worst-case single and multiple devices," and simulations in "10 cm increments." This suggests a comprehensive set of simulated scenarios rather than a traditional physical sample size.
    • Data Provenance: Not explicitly stated as "country of origin" or "retrospective/prospective" in the same way clinical data is. The data is generated through computational modeling and simulation using MED Institute's FDA-qualified Medical Device Development Tool (MDDT) and the Duke virtual human anatomy. This is a form of prospective simulation data.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable in the traditional sense for this type of non-clinical, simulation-based study. The "ground truth" for the RF-induced heating simulations is derived from the established physics and engineering principles embedded in the FDA-qualified MDDT and the Duke virtual human anatomy model. The expertise lies in the development and validation of these computational tools and the interpretation of the simulation results by experts in MR safety and medical device engineering at MED Institute and the submitting company. The document does not specify the number or qualifications of individual experts validating the computational model, but implies that the MDDT itself is "FDA-qualified," indicating a level of expert review and agreement on its methodology.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set

    Not applicable. Adjudication methods like "2+1" or "3+1" are typically used for consensus building among human expert readers for clinical studies, especially when establishing ground truth from image interpretation. This study is based on physical property testing and computational simulations, not human interpretation of clinical data.

    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 a study involving human readers or AI-assisted diagnostic performance. It focuses on the physical safety of implants in an MR environment.

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

    The RF-induced heating assessment involved "Computational modeling and simulation (CM&S) ... using MED Institute's FDA-qualified Medical Device Development Tool (MDDT) and in a clinically relevant position within the Duke virtual human anatomy." This is a standalone algorithm/model-based assessment without a human-in-the-loop for the performance evaluation itself. Human experts design the simulations, configure the models, and interpret the results, but the "performance" (temperature rise, SAR calculations) is computed by the algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    For the non-clinical tests:

    • Magnetically induced displacement force, torque, and image artifacts: The "ground truth" is based on the physical properties of the materials and device designs, measured or calculated according to established ASTM standards (F2052-21, F2213-17, F2119-07).
    • RF-induced heating: The "ground truth" for the simulations is derived from the established electromagnetic physics and thermal dynamics principles implemented in the FDA-qualified Medical Device Development Tool (MDDT) and applied to the Duke virtual human anatomy model. The MDDT's qualification process by the FDA implicitly establishes the reliability of its results as a form of "ground truth" for simulation-based assessments.

    8. The sample size for the training set

    Not applicable. This is a non-clinical study for MR safety assessment, not a machine learning model requiring a training set in the typical sense. The "training" for the MDDT is its initial validation and qualification against known physical phenomena and experimental data, which is a separate process from this submission.

    9. How the ground truth for the training set was established

    Not applicable, as there is no training set for a machine learning model in this context. The "ground truth" for qualifying the simulation tool (MDDT) would have been established through extensive validation against experimental measurements and recognized physical theories.

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    K Number
    K210731
    Manufacturer
    Date Cleared
    2022-07-18

    (494 days)

    Product Code
    Regulation Number
    872.4760
    Panel
    Dental
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K943347, K170272, K182789

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

    KLS Martin Individual Patient Solutions (IPS) is intended as a pre-operative software tool for simulating / evaluating surgical treatment options as a software and image segmentation system for the transfer of imaging information from a medical scanner such as a CT based system. The is processed by the IPS software and the result is an output data file that may then be provided as digital models or used as input in an additive manufacturing portion of the system that produces physical outputs including implants, anatomical models, guides, splints, and case reports for use in maxillofacial, midface, & mandibular surgery.

    KLS Martin Individual Patient Solutions (IPS) implant devices are intended for use in the stabilization, fixation, and reconstruction of the maxillofacial / midface and mandibular skeletal regions in children (2 years of age), adolescents (12 years of age - 21 years of age), and adults.

    Device Description

    KLS Martin Individual Patient Solutions (IPS) is comprised of a collection of software and associated additive manufacturing equipment intended to produce various outputs to support reconstructive and orthognathic surgeries. The system processes the medical images to produce various patient-specific physical and/or digital output devices which include implants, anatomical models, guides, splints, and case reports.

    Patient-specific metallic bone plates are used in conjunction with metallic bone screws for internal fixation of maxillofacial, midface, and mandibular bones. The devices are manufactured based on medical imaging (CT scan) of the patient's anatomy with input from the physician during virtual planning and prior to finalization and production of the device. The physician provides input for model manipulation and interactive feedback by viewing digital models of planned outputs that are modified by trained KLS Martin engineers during the planning session. For each design iteration, verification is performed by virtually fitting the generated output device over a 3D model of the patient's anatomy to ensure its dimensional properties allow an adequate fit.

    Implants are provided non-sterile and are manufactured using traditional (subtractive) or additive manufacturing methods from either CP Titanium (ASTM F67) or Ti-6AI-4V (ASTM F136). These patient-specific devices are fixated with previously cleared KLS Martin screws.

    AI/ML Overview

    Here's a summary of the acceptance criteria and study information for the KLS Martin Individual Patient Solutions device, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for the KLS Martin Individual Patient Solutions device primarily revolve around demonstrating substantial equivalence to predicate devices and ensuring the safety and effectiveness of the device, particularly for the expanded pediatric population and new specifications. The performance is assessed through various non-clinical tests and a review of clinical literature.

    Acceptance Criteria CategorySpecific Criteria/TestsReported Device Performance
    Material PropertiesBiocompatibility (ISO 10993-1)Cytotoxicity, chemical analysis, sensitization, irritation, and chemical/material characterization leveraged from predicate/reference devices for titanium, synthetic polymers, and acrylic resins. New photopolymer resin for splints passed cytotoxicity, sensitization, irritation, and material-mediated pyrogenicity testing.
    Mechanical PropertiesBending Resistance and Fatigue Life (ASTM F382)Determined to be substantially equivalent to K943347 plates (reference device). New worst-case midface, orbit, and mandible plate designs were tested.
    SterilizationSterility Assurance Level (SAL) of 10^-6 (ISO 17665-1:2006)Validations for titanium devices leveraged from K191028. Validations for synthetic polymers and acrylic resins leveraged from K182789. New photopolymer resin for splints also underwent sterilization validation, with acceptance criteria met.
    PyrogenicityLAL endotoxin testing (AAMI ANSI ST72)Endotoxin levels below USP allowed limit for medical devices, meeting pyrogen limit specifications. Leveraged from K191028 for titanium devices.
    Software PerformanceSoftware Verification and ValidationObjective evidence that all software requirements and specifications were correctly and completely implemented, traceable to system requirements. Demonstrated conformity with predefined specifications and acceptance criteria.
    Clinical Performance (Pediatric Expansion)Risk mitigation assessments (FDA Guidance "Premarket Assessment of Pediatric Medical Devices") and review of peer-reviewed clinical literature.Risk assessments addressed various pediatric risk factors. Six clinical studies (patients 18 months to 18 years) were analyzed to support safety and effectiveness in pediatric subpopulations (2 to
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    K Number
    K182758
    Device Name
    MCI - CMF System
    Date Cleared
    2019-12-05

    (433 days)

    Product Code
    Regulation Number
    872.4760
    Panel
    Dental
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    MCI - CMF System is intended for use in selective trauma of the midface, maxillofacial surgery, reconstructive procedures, and selective orthognathic surgery of the maxilla, mandible and chin.

    Device Description

    The bone plates are made from commercially pure titanium (ASTM F67) and the bone screws are manufactured from titanium alloy - Ti-6AI-4V (ASTM F136) and are available in different sizes and shapes, according the site of the implantation and the extension of the fracture. The surface of plates and screws are colored-anodized. MCI - CMF System implant devices are for single use. The devices are provided non-sterile and must be properly cleaned, disinfected and sterilized before use, according the recommendations provided in the Instructions for Use.

    AI/ML Overview

    I am sorry, but the provided text describes a 510(k) premarket notification for a medical device called the "MCI - CMF System," which consists of bone plates and screws. This document focuses on demonstrating substantial equivalence to existing predicate devices, primarily through comparison of design, materials, indications for use, and a limited set of mechanical and biocompatibility tests.

    There is no mention of an AI/algorithm-driven device, nor are there any acceptance criteria or studies related to AI model performance, accuracy, or human-in-the-loop studies involving expert readers.

    Therefore, I cannot fulfill your request to describe acceptance criteria and a study that proves a device meets acceptance criteria in the context of an AI/algorithm. The provided text simply does not contain this information.

    To elaborate on why I cannot answer based on the provided text:

    • No AI/Algorithm: The "MCI - CMF System" is a physical medical implant (bone plates and screws). It is not software, an algorithm, or an AI system.
    • No Diagnostic Claims: The device is for "selective trauma of the midface, maxillofacial surgery, reconstructive procedures, and selective orthognathic surgery of the maxilla, mandible and chin." These are surgical indications, not diagnostic. There's no AI that would be "reading" images or assisting in diagnosis.
    • No Acceptance Criteria for AI Performance: Since it's a physical implant, the "performance" data refers to mechanical testing (e.g., bending fatigue of plates, pullout strength of screws) and biocompatibility, not AI metrics like sensitivity, specificity, AUC, or reader studies.
    • No Test Set Details: There's no test set of patient data, as there's no AI to evaluate on such data.
    • No Expert Ground Truth or Adjudication: These concepts are relevant for evaluating AI in diagnostic imaging or clinical decision support, which is not the function of this device.
    • No MRMC or Standalone AI Study: These are types of studies specifically for AI performance evaluation.
    • No Training Set Information: Again, training sets are for machine learning models, which are not described in this document.

    The 510(k) summary concludes that the device is substantially equivalent based on engineering principles, material science, and the stated indications for use, compared to predicate devices already on the market.

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    K Number
    K182789
    Manufacturer
    Date Cleared
    2019-03-11

    (161 days)

    Product Code
    Regulation Number
    872.4120
    Panel
    Dental
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K163579, K943347, K971297

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

    The KLS Martin Individual Patient Solutions (IPS) Planning System is intended for use as a software system and image segmentation system for the transfer of imaging information from a medical scanner such as a CT based system. The input data file is processed by the IPS Planning System and the result is an output data file that may then be provided as digital models or used as input to a rapid prototyping portion of the system that produces physical outputs including anatomical models, guides, splints, and case reports for use in maxillofacial surgery. The IPS Planning System is also intended as a pre-operative software tool for simulating / evaluating surgical treatment options.

    Device Description

    The KLS Martin Individual Patient Solutions (IPS) Planning System is a collection of software and associated additive manufacturing (rapid prototyping) equipment intended to provide a variety of outputs to support reconstructive and orthognathic surgeries. The system uses electronic medical images of the patients' anatomy (CT data) with input from the physician, to manipulate original patient images for planning and executing surgery. The system processes the medical images and produces a variety of patient specific physical and/or digital output devices which include anatomical models, guides, splints and case reports.

    AI/ML Overview

    The provided text describes the KLS Martin Individual Patient Solutions (IPS) Planning System and its regulatory clearance (K182789) by the FDA. However, it does not contain information about a study proving the device meets specific acceptance criteria in the context of an AI/algorithm's performance.

    Instead, the document is a 510(k) summary demonstrating substantial equivalence to a predicate device (K181241), primarily to expand the patient population to include pediatric subgroups. The core of the device is a planning system involving commercial off-the-shelf (COTS) software and additive manufacturing for physical outputs, with human-in-the-loop interaction from trained employees/engineers and physicians.

    Therefore, most of the requested information regarding AI acceptance criteria, performance metrics, sample sizes, ground truth establishment, expert adjudication, and MRMC studies is not present in the provided document. The device, as described, is not an AI algorithm in the sense that it performs automated diagnostic or treatment recommendations independently based on image analysis with defined metrics. It's a system to assist human planning processes.

    Here's an analysis based on the information available in the document, and a clear indication of what is not available.


    Acceptance Criteria and Device Performance (as far as applicable from the document)

    The document focuses on demonstrating substantial equivalence, not on acceptance criteria for a freestanding AI algorithm's performance. The "performance" described is primarily related to material properties, biocompatibility, and sterilization, and the functioning of the software as a tool for human planning.

    Acceptance Criteria (Inferred from Substantial Equivalence and Safety/Performance)Reported Device Performance (from document)
    Material Degradation (Polyamide Guides)Subject polyamide guides can withstand multiple sterilization cycles without degradation and can maintain 85% of its initial tensile strength. Demonstrates shelf life of 6 months. (p.10)
    Titanium Device EquivalencyAdditively manufactured titanium devices are equivalent to, or better than, titanium devices manufactured using traditional (subtractive) methods, leveraging data from reference device K163579. (p.10)
    BiocompatibilityBiocompatibility endpoints (cytotoxicity, sensitization, irritation, chemical/material characterization) for both polyamide and titanium manufactured devices met pre-defined acceptance criteria (leveraged from predicate K181241 and reference K163579). (p.10)
    Sterility Assurance Level (SAL)Achieved an SAL of 10^-6 for each output device using the biological indicator (BI) overkill method for steam sterilization. Validations for polyamide and titanium leveraged from predicate K181241 and reference K163579. (p.10)
    Pyrogenicity (Endotoxin Levels)Endotoxin levels were below the USP allowed limit for medical devices and met pyrogen limit specifications, leveraging data from reference device K163579 for titanium. (p.10)
    Software Functionality and ValidationQuality and on-site user acceptance testing provided objective evidence that all software requirements and specifications were implemented correctly and completely and are traceable to system requirements. Testing from risk analysis showed conformity with pre-defined specifications and acceptance criteria. Software documentation demonstrates mitigation of potential risks and performance as intended. (p.11, p.14)
    Safety and Effectiveness in Pediatric SubpopulationsA risk assessment based on FDA guidance and supporting peer-reviewed clinical literature was performed. The conclusion is that expanding the patient population to neonates, infants, and children does not identify new issues of safety or effectiveness and the device is substantially equivalent to the predicate. (p.5, p.11, p.14) Note: This is a risk assessment and literature review, not a new clinical performance study.

    Information NOT Available in the Document (as it pertains to an AI/Algorithm performance study):

    1. Sample size used for the test set and data provenance:
      This information is not provided. The study performed was primarily non-clinical (material testing, biocompatibility, sterilization) and a risk assessment for pediatric use, not a clinical trial evaluating algorithm performance on a test set of patient data.

    2. Number of experts used to establish the ground truth for the test set and their qualifications:
      Not applicable, as no dedicated test set for evaluating AI/algorithm performance against a ground truth is described. The system relies on physician input and interaction with trained employees/engineers for planning, not on an autonomous algorithmic output that requires expert adjudication for ground truth.

    3. Adjudication method for the test set:
      Not applicable for the same reasons as above.

    4. If a multi-reader multi-case (MRMC) comparative effectiveness study was done:
      No, an MRMC comparative effectiveness study was not done. The document explicitly states: "Clinical testing was not necessary for the determination of substantial equivalence." (p.11, p.14). The device is a planning system with human-in-the-loop, not an AI intended to improve human readers' performance directly.

    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
      No, a standalone algorithm performance study was not described. The device is presented as a "software system and image segmentation system" where "trained employees/engineers... manipulate data and work with the physician to create the virtual planning session." (p.4, p.13) The core function described is human-assisted planning and production of physical models, not an autonomous algorithmic output.

    6. The type of ground truth used:
      Ground truth in the context of an AI algorithm's diagnostic or predictive performance is not relevant here, as no such AI is described. The "ground truth" for the device's function would relate to the accuracy of the generated physical models and plans relative to the patient's anatomy and surgical intent, which is managed through human interaction and validation within the system's intended use.

    7. The sample size for the training set:
      Not applicable. The document refers to "commercially off-the-shelf (COTS) software applications" (p.4, p.13) which implies existing, validated software tools are being used, not a newly developed AI model requiring a separate training set.

    8. How the ground truth for the training set was established:
      Not applicable, as no new training set for an AI model is described.

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    K Number
    K181241
    Manufacturer
    Date Cleared
    2018-09-13

    (126 days)

    Product Code
    Regulation Number
    872.4120
    Panel
    Dental
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K163579, K943347, K971297

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

    The KLS Martin Individual Patient Solutions (IPS) Planning System is intended for use as a software system and image segmentation system for the transfer of imaging information from a medical scanner such as a CT based system. The input data file is processed by the IPS Planning System and the result is an output data file that may then be provided as digital models or used as input to a rapid prototyping portion of the system that produces physical outputs including anatomical models, guides, splints, and case reports for use in maxillofacial surgery. The IPS Planning System is also intended as a pre-operative software tool for simulating / evaluating surgical treatment options.

    Device Description

    The KLS Martin Individual Patient Solutions (IPS) Planning System is a collection of software and associated additive manufacturing (rapid prototyping) equipment intended to provide a variety of outputs to support reconstructive and orthognathic surgeries. The system uses electronic medical images of the patients' anatomy (CT data) with input from the physician, to manipulate original patient images for planning and executing surgery. The system processes the medical images and produces a variety of patient specific physical and/or digital output devices which include anatomical models, guides, splints and case reports.

    AI/ML Overview

    Here's an analysis of the acceptance criteria and study information based on the provided text, focusing on what is present and what is not:

    The document (K181241 510(k) Summary) describes the KLS Martin Individual Patient Solutions (IPS) Planning System, which is a software system for image segmentation and pre-operative planning, and also provides physical outputs like anatomical models, guides, and splints for maxillofacial surgery. The submission focuses on demonstrating substantial equivalence to a predicate device (VSP System K120956) and uses several reference devices.

    Acceptance Criteria and Study Information:

    Based on the provided text, the device itself is a planning system that ultimately produces physical outputs. The "performance" being evaluated relates to the characteristics of these physical outputs (tensile strength, biocompatibility, sterility, pyrogenicity) and the software's functionality. There isn't a direct "device performance" metric in the traditional sense of an AI diagnostic device's sensitivity, specificity, or accuracy against a clinical outcome.

    1. Table of Acceptance Criteria and Reported Device Performance

    Given the nature of the device (planning system with physical outputs, not a diagnostic AI), the performance metrics are primarily related to safety and manufacturing quality.

    Acceptance Criteria CategorySpecific Acceptance Criteria (as implied)Reported Device Performance (as summarized)
    Tensile & BendingPolyamide guides maintain 85% of initial tensile strength after multiple sterilization cycles. Demonstrate a 6-month shelf life. Titanium devices are equivalent or better than traditional methods.Polyamide guides met the criteria, demonstrating resistance to degradation after sterilization and supporting a 6-month shelf life. Titanium test results were leveraged from a reference device (K163579) and confirmed equivalence or superiority to traditional manufacturing.
    BiocompatibilityMeet pre-defined acceptance criteria for cytotoxicity, sensitization, irritation, and chemical/material characterization (according to ISO 10993-1).All conducted tests (cytotoxicity, sensitization, irritation, chemical/material characterization) for subject devices (polyamide and titanium) were within pre-defined acceptance criteria. Titanium results also leveraged from K163579.
    SterilizationAchieve a Sterility Assurance Level (SAL) of 10^-6 for each output device using the BI overkill method for steam sterilization (according to ISO 17665-1:2006 for dynamic-air-removal cycle).All test method acceptance criteria were met, achieving the specified SAL of 10^-6. Validations for titanium were leveraged from K163579.
    PyrogenicityMeet pyrogen limit specifications, with endotoxin levels below USP allowed limit for medical devices (according to AAMI ANSI ST72 for LAL endotoxin testing).The devices contain endotoxin levels below the USP allowed limit for medical devices and meet pyrogen limit specifications. Testing for titanium was leveraged from K163579.
    Software Verification & Validation (V&V)All software requirements and specifications are implemented correctly and completely, traceable to system requirements. Conformity with pre-defined specifications and acceptance criteria based on risk analysis and impact assessments. Mitigation of potential risks and performance as intended based on user requirements.Quality and on-site user acceptance testing provided objective evidence of correct and complete implementation of software requirements, traceability, and conformity with specifications and acceptance criteria. Software documentation demonstrated risk mitigation and intended performance. (Note: Specific quantitative metrics for software performance are not provided in this summary).

    2. Sample size used for the test set and the data provenance

    • Test Set Sample Size: The document does not specify a "test set" in the context of a dataset for evaluating AI performance (e.g., medical images for segmentation accuracy). Instead, "testing" refers to non-clinical performance evaluations of the physical outputs and software.
      • For Tensile & Bending, Biocompatibility, Sterilization, and Pyrogenicity, the sample sizes are not explicitly mentioned, but the tests were performed on "the subject polyamide guides" and "titanium" components. The provenance is internal testing performed by the manufacturer, or results leveraged from previous KLS Martin device submissions.
      • For Software V&V, no specific numerical "test set" of software inputs is given, but testing was performed on "each individual software application."
    • Data Provenance: The data provenance for non-clinical testing is internal to the manufacturer or relied upon previous regulatory submissions for similar materials/processes. It is not patient or country-specific data as would be for clinical studies. The data used by the IPS Planning System itself (CT data) would be patient data, but the evaluation here is of the system's outputs, not its interpretation of patient data in a diagnostic manner. The document states the system "transfers imaging information from a medical scanner such as a CT based system."

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    • This question is not applicable in the context of this 510(k) submission. The "ground truth" for the non-clinical tests (tensile strength, biocompatibility, etc.) is established by standard scientific and engineering methodologies, not by expert medical review of images.
    • For the "Software Verification and Validation," the "ground truth" for software functionality is defined by the established software requirements and specifications, validated by internal quality and user acceptance testing, not by external experts in the medical domain. The document mentions "input from the physician" for manipulation of original patient images, suggesting physicians set the clinical goals for the plan, but the validation of the system's performance is not described as involving experts establishing a "ground truth" concerning image interpretation.

    4. Adjudication method for the test set

    • Not applicable. There is no adjudication method described as would be used for clinical interpretation or diagnostic performance evaluation by multiple experts. The non-clinical tests follow established standards and protocols.

    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, a multi-reader multi-case (MRMC) comparative effectiveness study was not done.
    • This device is a planning system for maxillofacial surgery, not a diagnostic AI that assists human readers in image interpretation or diagnosis. It aids in surgical planning and creates physical outputs. The submission explicitly states: "Clinical testing was not necessary for the determination of substantial equivalence."

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

    • Given the device's function, it is inherently a "human-in-the-loop" system. The description states: "The system uses electronic medical images of the patients' anatomy (CT data) with input from the physician, to manipulate original patient images for planning and executing surgery." And, "The physician provides input for model manipulation and interactive feedback through viewing of digital models...that are modified by the trained employee/engineer during the planning session."
    • Therefore, performance of the algorithm without human intervention is not the intended use or focus of this submission. The "software verification and validation" (Section 11) is the closest thing to an "algorithm-only" evaluation, but it's about software functionality, not standalone image interpretation performance.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    • For the non-clinical performance tests of the physical outputs (Tensile & Bending, Biocompatibility, Sterilization, Pyrogenicity), the "ground truth" is defined by established engineering and scientific standards (e.g., ISO 10993-1, ISO 17665-1:2006, AAMI ANSI ST72, and internal specifications).
    • For Software Verification & Validation, the "ground truth" is adherence to predefined software requirements and specifications (functional and non-functional, related to image transfer, manipulation, and output file generation). It is not based on medical "ground truth" like pathology or clinical outcomes.

    8. The sample size for the training set

    • This question is not applicable. The KLS Martin IPS Planning System is described as using "validated commercially off-the-shelf (COTS) software applications" for image manipulation. There is no mention of a "training set" in the context of machine learning or AI model development within this summary. It appears to be a rule-based or conventional algorithmic system rather than a deep learning/machine learning model that would require a distinct training set.

    9. How the ground truth for the training set was established

    • This question is not applicable, as no training set for machine learning was mentioned or identified in the document (see point 8).
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    K Number
    K163579
    Manufacturer
    Date Cleared
    2017-11-21

    (336 days)

    Product Code
    Regulation Number
    872.4760
    Panel
    Dental
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K062570, K943347, K971297, K153482

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

    KLS Martin Individual Patient Solutions implant devices are in the stabilization and fixation of mandibular fractures and mandibular reconstruction.

    Device Description

    KLS Martin Individual Patient Solutions is comprised of patient-specific models and metallic bone plates used in conjunction with metallic bone screws for internal fixation of mandibular bone. The devices are manufactured based on medical imaging (CT scan) of the patient's anatomy with input from the physician during virtual planning and prior to finalization and production of the device. The physician only provides input for model manipulation and interactive feedback by viewing digital models of planned outputs that are modified by trained KLS Martin engineers during the planning session. For each design iteration, verification is performed by virtually fitting the generated device model over a 3D model of the patient's anatomy to ensure its dimensional properties allow an adequate fit. Implants are provided non-sterile, range in thickness from 1.0 - 3.0 mm, and are manufactured using traditional (subtractive) or rapid prototyping (additive) methods from either CP Titanium (ASTM F67) or Ti-6Al-4V (ASTM F136) materials. These patient-specific devices are fixated with previously cleared KLS Martin screws.

    AI/ML Overview

    Here's a summary of the acceptance criteria and study information for the KLS Martin Individual Patient Solutions device, based on the provided document:

    This document focuses on the mechanical and material performance of the device rather than the performance of an AI algorithm in a diagnostic or clinical decision support context. Therefore, many of the typical AI/ML study questions (like effect size of human readers with/without AI, standalone algorithm performance, number of experts for ground truth, etc.) are not applicable here.


    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria / Performance MetricReported Device Performance
    Mechanical Performance (Bending Properties per ASTM F382)The bending resistance and fatigue life of the subject devices (additive manufactured) were determined to be equivalent or better than the predicate devices (subtractive manufactured).
    Sterilization Validation (Steam Sterilization per ISO 17665-1:2006)Validation performed for the dynamic-air-removal cycle to a sterility assurance level (SAL) of $10^{-6}$ using the biological indicator (BI) overkill method. All test method acceptance criteria were met.
    Biocompatibility (per ISO 10993)The battery of cytotoxicity, chemical analysis, sensitization and irritation, and chemical/material characterization testing conducted on the subject device were within the pre-defined acceptance criteria, and therefore, adequately addresses biocompatibility for implants with a permanent duration of contact.
    Verification of Patient-Specific DesignFor each design iteration, verification is performed by virtually fitting the generated device model over a 3D model of the patient's anatomy to ensure its dimensional properties allow an adequate fit. (This is a design verification process, not clinical performance for the manufactured implant).

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

    • Test Set Sample Size: Not explicitly stated in terms of number of physical devices or specific data points for performance testing. The document refers to "the subject plates" for mechanical testing, implying a representative sample was tested.
    • Data Provenance: The studies are non-clinical bench tests and conducted by the manufacturer, KLS Martin LP. The data originates from these laboratory tests, not from patient data or clinical settings. It is a retrospective analysis of device performance against established standards.

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

    • This device is a medical implant, not a diagnostic AI device. There is no concept of "ground truth" established by human experts in the context of diagnostic interpretation for its performance testing. The "ground truth" for its performance is derived from established engineering and materials science standards (ASTM, ISO, etc.).

    4. Adjudication Method for the Test Set

    • Not applicable. The performance tests are objective measurements against engineering standards, not subjective interpretations requiring adjudication.

    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 medical implant, not an AI diagnostic or decision support tool. No human reader studies with or without AI assistance were conducted or are relevant.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    • Not applicable. This is a medical implant. The "algorithm" in this context refers to the manufacturing process driven by patient CT data and physician input for design, not an AI algorithm for diagnosis or interpretation. The device itself is "standalone" in that it performs its mechanical function once implanted, but its pre-market testing does not involve "algorithm-only performance" as would be understood for an AI/ML product.

    7. The Type of Ground Truth Used

    • Engineering Standards and Specifications: The "ground truth" for this device's performance is derived from compliance with established international standards for medical devices and materials, specifically:
      • ASTM F382 (Standard Specification for Metallic Bone Plates) for mechanical performance.
      • 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) for sterilization.
      • ISO 10993 (Biological evaluation of medical devices) for biocompatibility.
    • For the patient-specific design process, the "ground truth" for dimensional fit is a virtual fitting against a 3D model of the patient's anatomy derived from a CT scan.

    8. The Sample Size for the Training Set

    • Although the device design is patient-specific and involves a "virtual planning" phase, this is not an AI/ML product that learns from a "training set" in the conventional sense. Each device is unique to a patient based on their CT scan. The "training" for the manufacturing process (both traditional and additive) happens through engineering validation and quality control procedures, not through a data-driven training set for an algorithm.

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

    • Not applicable, as there is no traditional "training set" for an AI/ML algorithm. The "ground truth" for the device's manufacturing and material properties is established through adherence to design specifications, material standards (ASTM F67, ASTM F136), and manufacturing quality control processes. The patient's CT scan provides the anatomical data for each individual device's design.
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    K Number
    K163315
    Manufacturer
    Date Cleared
    2017-05-05

    (163 days)

    Product Code
    Regulation Number
    882.5330
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K943347, K944561, K944565, K971297, K060177

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

    Internal Distraction - Sterile includes devices intended as bone stabilizers and lengthening (and or transport) devices for correction of congenital deficiencies or post traumatic defects of the cranial bones that require gradual distraction.

    Device Description

    Internal Distraction - Sterile consists of sterile internal distraction devices intended for the correction of cranial bones that are comprised of several different designs and components intended for bone stabilization and elongation through distraction osteogenesis. It is composed of multiple sizes and shapes of distractor footplates and either fixed or detachable activator arms. The devices are positioned internally with a connected activation arm extending through the soft tissue for external activation. Some devices, due to their anatomical positioning, are directly activated using a patient activation driver, eliminating the need for attaching an activation arm to the device. The distractor footplates are fixated to the bone on either side of the osteotomy using previously cleared bone screws (K943347, K944561, K944565, K971297, K060177). Distraction is achieved by rotating the distractor threaded drive screws with the patient driver, often with an activation arm, which causes a separation of the distractor footplates and induces the body to grow bone and expand soft tissue as a response. Various lengths of distractor drive screws are available to achieve the desired distraction length. Upon completion of distraction and consolidation of the bone, the screws are removed from the footplates and the distractor is explanted.

    AI/ML Overview

    This document is a 510(k) premarket notification for the "Internal Distraction - Sterile" device. The acceptance criteria and supporting studies are based on demonstrating substantial equivalence to a predicate device, the "Zurich Distraction System (K010139)".

    Here's a breakdown of the requested information:

    1. A table of acceptance criteria and the reported device performance

    Acceptance Criteria CategoryAcceptance CriteriaReported Device Performance
    Intended UseThe device is intended as a bone stabilizer and lengthening/transport device for correction of congenital deficiencies or post-traumatic cranial bone defects requiring gradual distraction.The "Internal Distraction - Sterile" device has the same intended use as the predicate device, specifically for cranial bones.
    Materials/BiocompatibilityMaterials (Titanium Alloy (Ti-6Al-4V) and CP Titanium) should meet biocompatibility requirements as per FDA Blue Book Memo #G95-1 (ISO 10993 Part 1).The device uses the same materials (Titanium Alloy (Ti-6Al-4V) and CP Titanium) as the previously cleared predicate device, with identical chemical composition, manufacturing processes, and body contact duration. Therefore, no new biocompatibility testing was needed or performed.
    Sterilization & PyrogenicityDevice must be in sterile packaging and meet pyrogenicity limits.Bacterial Endotoxins testing was conducted (ANSI/AAMI ST72:2011, USP , EP 2.6.14). Results demonstrate conformity to required endotoxin units per device and meet pyrogen limit specifications. The device will be provided sterile via gamma irradiation.
    Mechanical PerformanceMechanical properties (axial resistance, torsional loading, material properties, manufacturing tolerances) must be sufficient to withstand anatomical loads and allow for effective and safe bone movement.Axial load testing, bending torsion testing, axial-torsion testing, and transverse shear testing were performed. All devices passed design requirements for material properties, manufacturing tolerances, axial resistance, and torsional loading, demonstrating sufficient capability to withstand anatomical loads and allow effective/safe boney movement.
    Substantial EquivalenceThe device must be substantially equivalent to the predicate device in intended use, design, function, manufacturing process, and materials, such that any differences do not raise new questions of safety or effectiveness.The device is similar to the predicate in intended use, design, function, manufacturing process, and materials. Differences (sterile packaging, cranial-specific indication, ratcheting mechanism, detachable activators) were deemed not to raise new questions of safety or effectiveness.

    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 primarily relies on non-clinical performance data (bench testing) and comparison to the predicate device.

    • Biocompatibility: No new testing was performed; it relied on the predicate device's clearance.
    • Pyrogenicity: The sample size for Bacterial Endotoxins testing is not specified.
    • Mechanical Performance: The sample size for axial load, bending torsion, axial-torsion, and transverse shear testing is not specified. This was bench testing, not clinical data, so provenance like "country of origin" or "retrospective/prospective" is not applicable in the typical sense for patient data.

    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. The study is a 510(k) submission based on non-clinical bench testing and demonstration of substantial equivalence to a predicate device. There was no test set requiring expert ground truth for clinical cases.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. No clinical test set or adjudication for diagnostic ground truth was performed or required.

    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 medical implant (internal distraction system), not an AI-assisted diagnostic or therapeutic 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 is a medical device, not an algorithm, so the concept of standalone performance does not apply.

    7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)

    Not applicable in the context of clinical ground truth for diagnostic accuracy. The "ground truth" for this submission is based on:

    • Predicate Device Equivalence: The safety and effectiveness profile of the legally marketed predicate device (Zurich Distraction System, K010139).
    • Engineering Standards: Compliance with recognized standards for biocompatibility (ISO 10993-1), pyrogenicity (ANSI/AAMI ST72:2011, USP , EP 2.6.14), and mechanical performance through bench testing against design requirements.

    8. The sample size for the training set

    Not applicable. This is a medical device clearance, not an AI model. There is no concept of a "training set" for the device itself.

    9. How the ground truth for the training set was established

    Not applicable. See point 8.

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    K Number
    K161470
    Manufacturer
    Date Cleared
    2016-12-01

    (188 days)

    Product Code
    Regulation Number
    872.4760
    Panel
    Dental
    Why did this record match?
    Reference Devices :

    K943347, K944561, K944565, K971297, K060177

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

    Internal Distraction - Sterile includes devices intended as bone stabilizers and lengthening (and or transport) devices for correction of congenital deficiencies or post traumatic defects of the mandible (including ramus, body, alveolar ridge, palate, symphysis) and mid-face bones that require gradual distraction.

    Device Description

    Internal Distraction - Sterile consists of sterile internal distraction devices intended for the correction of the mandible and mid-face bones that are comprised of several different designs and components intended for bone stabilization and elongation through distraction osteogenesis. It is composed of multiple sizes and shapes of distractor footplates and either fixed or detachable activator arms. The devices are positioned internally with a connected activation arm extending through the soft tissue for external activation. Some devices, due to their anatomical positioning, are directly activated using a patient activation driver, eliminating the need for attaching an activation arm to the device. The distractor footplates are fixated to the bone on either side of the osteotomy using previously cleared bone screws (K943347, K944561, K944565, K971297, K060177). Distraction is achieved by rotating the distractor threaded drive screws with the patient driver, often with an activation arm, which causes a separation of the distractor footplates and induces the body to grow bone and expand soft tissue as a response. Various lengths of distractor drive screws are available to achieve the desired distraction length. Upon completion of distraction and consolidation of the bone, the screws are removed from the footplates and the distractor is explanted.

    AI/ML Overview

    This document describes a 510(k) premarket notification for the "Internal Distraction - Sterile" device. The submission focuses on demonstrating substantial equivalence to previously cleared predicate devices, primarily by indicating that the new device is a sterile version of existing non-sterile devices.

    Based on the provided document, here's a breakdown of the requested information:

    1. A table of acceptance criteria and the reported device performance

    The document does not explicitly state "acceptance criteria" in a quantitative, measurable sense for a clinical study. Instead, it describes general design requirements and performance evaluations for mechanical properties and biocompatibility. The "reported device performance" indicates that these requirements were met.

    Acceptance Criteria CategorySpecific Test/EvaluationReported Device Performance
    Mechanical PropertiesAxial Load TestingPassed design requirements for material properties, manufacturing tolerances, axial resistance, and torsional loading.
    Bending Torsion TestingPassed design requirements for material properties, manufacturing tolerances, axial resistance, and torsional loading.
    Axial-Torsion TestingPassed design requirements for material properties, manufacturing tolerances, axial resistance, and torsional loading.
    Transverse Shear TestingPassed design requirements for material properties, manufacturing tolerances, axial resistance, and torsional loading.
    Clinical RelevanceDevices are sufficiently capable of withstanding the anatomical loads placed upon them and allow for effective and safe boney movement during their intended use.
    BiocompatibilityGeneral BiocompatibilityNot needed directly for this submission as materials (Titanium Alloy (Ti-6Al-4V) and CP Titanium) were previously cleared and are identical to predicate devices.
    Endotoxin TestingConforms to required endotoxin units per device for medical devices and meets pyrogen limit specifications.

    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 for the test set: Not applicable (N/A). This submission did not involve a clinical study with a "test set" of patients. The performance data presented is from non-clinical bench testing and biocompatibility assessments of the device materials.
    • Data provenance: N/A. The data provenance described is related to bench testing, not patient data.

    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)

    • Number of experts: N/A. No clinical test set with ground truth established by experts was used.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set

    • Adjudication method: N/A. No clinical test set to adjudicate was utilized.

    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

    • MRMC study done: No. This is a medical device (bone plate/distractor) submission, not an AI/software as a medical device (SaMD) submission. An MRMC study would not be relevant in this context.
    • Effect size: N/A.

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

    • Standalone done: No. This submission is for a physical medical device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    • Type of ground truth: N/A. For the mechanical and biocompatibility testing, the "ground truth" is defined by established engineering and biological standards and specifications (e.g., design requirements, ANSI/AAMI ST72:2011, USP , EP 2.6.14 for endotoxins). No clinical ground truth (like expert consensus or pathology) was used as there was no clinical study.

    8. The sample size for the training set

    • Sample size for the training set: N/A. There was no "training set" in the context of an algorithm or AI. The design and manufacturing processes for the device are well-established based on existing predicate devices.

    9. How the ground truth for the training set was established

    • How ground truth was established for the training set: N/A. This concept is not applicable to the type of device and submission described.
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    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The sterile plate and screw kit configurations for use with the Bioplate® Titanium Fixation System are intended for use on non-load bearing fixation, including cranial bone fixation and brow fixation and the treatment of fractures and reconstructive procedures of the craniomaxillofacial skeleton. Each device is intended for single use only and only in conjunction with other titanium and titanium alloy implant

    Device Description

    The Bioplate® Titanium Fixation System includes a variety of plate configurations for different anatomical applications. Unalloyed commercially pure Grade 1, Grade 2 and Grade 4 titanium and titanium allov plates, and titanium allov screws of varying diameters and lengths are included for fixation of the plates to the craniomaxillofacial bony tissues. These materials have been implanted safely for many years. The predicate device had been approved under K022033.

    The bone plates will be manufactured of unalloyed, commercially pure titanium and titanium 6A1-4V Eli alloy. The materials adhere to the American Society of Testing and Materials (A.S.T.M.) F67 Standards and the American Society of Testing and Materials ( A.S.T.M.) F136 Standard.. The screw will be manufactured of a titanium 6A1-4V Eli alloy that meets the American Society of Testing and Materials (A.S.T.M.) F136 Standard.

    The plate and screw fit configurations are sterilized by gamma radiation sterilization, using VD Max dose setting method. Successful completion of sterilization validation and packaging validation studies provides a high level of assurance that sterility of the device has been achieved and can be maintained.

    AI/ML Overview

    The provided text is a 510(k) summary for a medical device (Modified Sterile Plate & Screw Kit Configurations for use with the Bioplate® Titanium Fixation System) and primarily focuses on establishing substantial equivalence to predicate devices, rather than presenting a performance study with specific acceptance criteria as would typically be seen for a new or novel device.

    Therefore, the document does not contain the information requested regarding:

    1. A table of acceptance criteria and reported device performance.
    2. Sample size used for the test set and data provenance.
    3. Number and qualifications of experts for ground truth establishment.
    4. Adjudication method for the test set.
    5. Multi-reader multi-case (MRMC) comparative effectiveness study or effect size.
    6. Standalone (algorithm-only) performance.
    7. Type of ground truth used (e.g., pathology, outcomes).
    8. Sample size for the training set.
    9. How ground truth for the training set was established.

    Instead, the document states:

    • Comparison of the device's technological characteristics with those of the predicate devices: "All the technical characteristics of the sterile plate and screw kit configurations for use Bioplate® Titanium Fixation System are substantially equivalent to the corresponding characteristics of the predicate devices, and any minor differences raise no new issues of safety and efficacy."
    • The materials used have been implanted safely for many years.
    • Sterilization validation and packaging validation studies were successfully completed, providing a high level of assurance of sterility.

    The "acceptance criteria" in this context are effectively demonstrating that the device is substantially equivalent to legally marketed predicate devices, meaning it has the same intended use, similar technological characteristics, and raises no new questions of safety or effectiveness. The study proving this involves comparing the new device's specifications (materials, sterilization method, intended use) against those of established predicate devices.

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    Why did this record match?
    Reference Devices :

    K910038, K944561, K944545, K943347, K974017, K945139

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

    The sterile plate and screw kit configurations for use with the Bioplate® Titanium Fixation System are intended for use in non-load bearing fixation, including, but not limited to cranial bone fixation and brow fixation, and the treatment of fractures and reconstructive procedures of the craniomaxillofacial skeleton. Each device is intended for single use only and only in conjunction with other titanium and titanium alloy implants.

    Device Description

    The sterile plate and screw kit configurations for use with the Bioplate® Titanium Fixation System includes a variety of plate confiqurations for different anatomical applications. Titanium alloy screws of varying lengths are included for fixation of the plates to the craniomaxillofacial bony tissue. Titanium alloy screws of varying lengths are included for fixation of the plates to the craniomaxillofacial bony tissue.

    The bone plates will be manufactured of unalloved, commercially pure titanium and titanium 6AI-4V ELI allov. The materials adhere to the American Society of Testing and Materials (A.S.T.M) F67 Standards and The American Society for Testing and materials (A.S.T.M.) F136 Standard. The screws will be manufactured of a titanium 6Al-4V ELI alloy that meets The American Society for Testing and materials (A.S.T.M.) F136 Standard.

    The plate and screw kit confiqurations are sterilized using gamma radiation sterilization methods. Successful completion of sterilization validation and packaging validation studies provides a high level of assurance that sterility of the devices has been achieved and can be maintained.

    AI/ML Overview

    This submission K022033 does not contain a study that describes acceptance criteria for device performance in the manner typically seen for software or AI/ML devices. This is a 510(k) premarket notification for a Class II medical device, specifically Sterile Plate & Screw Kit Configurations for use with the Bioplate® Titanium Fixation System.

    For devices like bone plates and screws, the "acceptance criteria" and "study" proving they meet those criteria are typically focused on substantial equivalence to predicate devices and adherence to established material and sterilization standards, rather than performance metrics like sensitivity, specificity, or accuracy.

    Here's a breakdown based on the provided document, addressing the requested points where applicable, and noting where the information is not present or not relevant to this type of device:


    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Inferred)Reported Device Performance (Inferred)
    Material Composition Standards:
    • Plates: Unalloyed, commercially pure titanium and titanium 6Al-4V ELI alloy, adhering to ASTM F67 and ASTM F136 Standards.
    • Screws: Titanium 6Al-4V ELI alloy, meeting ASTM F136 Standard. |
      | Sterilization Efficacy: |
    • Successfully completed sterilization validation studies proving sterility has been achieved.
    • Successfully completed packaging validation studies proving sterility can be maintained. |
      | Intended Use Equivalence: |
    • Intended for use in non-load bearing fixation, cranial bone fixation, brow fixation, and treatment of fractures and reconstructive procedures of the craniomaxillofacial skeleton.
    • Matches the indications for use of predicate devices: Bioplate, Inc., Wurzburg, Synthes, TiMesh, and KLS-Martin.
    • Intended for single use only. |
      | Technological Characteristics Equivalence: |
    • Same indications for use as predicate devices.
    • All technical characteristics are "substantially equivalent" to predicate devices.
    • "Minor differences raise no new issues of safety and efficacy." |
      | Manufacturing Quality System: |
    • Implicitly meets Good Manufacturing Practice (GMP) requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820), as mandated by FDA for all medical devices. (Mentioned in FDA letter as a general requirement, not a specific claim from the submitter). |
      | Safety and Efficacy (Overall Substantial Equivalence): |
    • Found substantially equivalent by FDA to legally marketed predicate devices, allowing it to proceed to market. The FDA letter states: "FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies." |

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    This information is not applicable and not provided in the document. This type of device (bone plates and screws) does not typically involve a "test set" in the context of diagnostic or AI/ML performance evaluation studies. The "testing" refers to material and sterilization validation, which are engineering and manufacturing tests, not clinical performance tests with patient data.

    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 information is not applicable and not provided. "Ground truth" for this device is established by adherence to engineering standards (ASTM), manufacturing specifications, and successful physical/chemical testing for material properties and sterility. It doesn't involve expert medical interpretation in the way an AI diagnostic device would.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    This information is not applicable and not provided. Adjudication methods are relevant for disputes in expert-labeled datasets, which is not the case here.

    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 information is not applicable and not provided. MRMC studies are used for evaluating diagnostic performance, often involving human readers and AI/ML systems. This is not a diagnostic device; it's a surgical implant.

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

    This information is not applicable and not provided. This device does not involve an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    The "ground truth" for this device is effectively established by:

    • Adherence to Material Standards: ASTM F67 and ASTM F136 specifications define the "truth" for material composition and properties.
    • Validation of Manufacturing Processes: Successful completion of sterilization validation and packaging validation studies (likely per ISO standards or similar) serves as "ground truth" for sterility.
    • Substantial Equivalence: The ultimate "ground truth" for marketing approval is that the device is substantially equivalent to predicate devices already on the market, meaning it performs as intended and introduces no new safety or efficacy concerns.

    8. The sample size for the training set

    This information is not applicable and not provided. There is no "training set" in the context of an AI/ML algorithm for this device.

    9. How the ground truth for the training set was established

    This information is not applicable and not provided. There is no "training set" or "ground truth" establishment in the AI/ML sense for this device.

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