EPIC Extremity Fusion Plate System

K182991 · Epic Extremity, LLC · HRS · Feb 13, 2019 · Orthopedic

Device Facts

Record IDK182991
Device NameEPIC Extremity Fusion Plate System
ApplicantEpic Extremity, LLC
Product CodeHRS · Orthopedic
Decision DateFeb 13, 2019
DecisionSESE
Submission TypeTraditional
Regulation21 CFR 888.3030
Device ClassClass 2
AttributesTherapeutic

Intended Use

The EPIC Extremity Fusion Plate System is indicated for use in stabilization of fresh fractures, revision procedures, joint fusion and reconstruction of small bones of the feet and ankles, including distal tibia. The plates/screws are intended for single use only.

Device Story

System consists of metallic bone plates and locking/non-locking screws (4.5mm/5.5mm) and cannulated cancellous screws; used for internal fixation of small bones in feet and ankles. Implants are surgically placed by orthopedic surgeons to stabilize fractures or facilitate fusion/reconstruction. System includes specialized instrumentation for implantation. Device provides mechanical stabilization to bone segments to promote healing and restore structural integrity. Single-use only.

Clinical Evidence

No clinical testing was required. Substantial equivalence supported by non-clinical performance data (cross-sectional analysis of bending strength).

Technological Characteristics

Metallic bone fixation system; includes plates and 4.5mm/5.5mm locking/non-locking/cannulated screws. Materials are identical to predicate devices. Designed for surgical implantation in small bones of feet/ankles.

Indications for Use

Indicated for stabilization of fresh fractures, revision procedures, joint fusion, and reconstruction of small bones of the feet and ankles, including the distal tibia.

Regulatory Classification

Identification

Single/multiple component metallic bone fixation appliances and accessories are devices intended to be implanted consisting of one or more metallic components and their metallic fasteners. The devices contain a plate, a nail/plate combination, or a blade/plate combination that are made of alloys, such as cobalt-chromium-molybdenum, stainless steel, and titanium, that are intended to be held in position with fasteners, such as screws and nails, or bolts, nuts, and washers. These devices are used for fixation of fractures of the proximal or distal end of long bones, such as intracapsular, intertrochanteric, intercervical, supracondylar, or condylar fractures of the femur; for fusion of a joint; or for surgical procedures that involve cutting a bone. The devices may be implanted or attached through the skin so that a pulling force (traction) may be applied to the skeletal system.

Predicate Devices

Reference Devices

Related Devices

Submission Summary (Full Text)

{0}------------------------------------------------ Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters 'FDA' in a blue square, followed by the words 'U.S. FOOD & DRUG ADMINISTRATION' in blue text. EPIC Extremity, LLC Randy Schlemmer Director of Product Development 120 Marguerite Drive. Suite 301 Cranberry Twp, Pennsylvania 16066 February 13, 2019 # Re: K182991 Trade/Device Name: EPIC Extremity Fusion Plate System Regulation Number: 21 CFR 888.3030 Regulation Name: Single/Multiple Component Metallic Bone Fixation Appliances And Accessories Regulatory Class: Class II Product Code: HRS Dated: January 7, 2019 Received: January 9, 2019 ### Dear Randy Schlemmer: We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrl/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading. If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please be advised that 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. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for {1}------------------------------------------------ devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm. For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100). Sincerely, Image /page/1/Picture/11 description: The image shows a digital signature. The signature is for Jesse Muir -S. The date of the signature is 2019.02.13 and the time is 10:16:53-05'00'. For 10:16:53 -05'00' Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration ## Indications for Use 510(k) Number (if known) K182991 Device Name EPIC Extremity Fusion Plate System #### Indications for Use (Describe) The EPIC Extremity Fusion Plate System is indication of fresh fractures, revision procedures, joint fusion and reconstruction of small bones of the feet and ankles, including distal tibia. The plates/screws are intended for single use only. Type of Use (Select one or both, as applicable) > Prescription Use (Part 21 CFR 801 Subpart D) Over-The-Counter Use (21 CFR 801 Subpart C) #### CONTINUE ON A SEPARATE PAGE IF NEEDED. This section applies only to requirements of the Paperwork Reduction Act of 1995. #### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.* The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to: > Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number." Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below. {3}------------------------------------------------ Image /page/3/Picture/1 description: The image shows the word "EPIC" in large, bold, black letters. Below the word "EPIC" is the word "EXTREMITY" in smaller, white letters against a blue and gray gradient background. The word "EPIC" is the main focus of the image, and the word "EXTREMITY" appears to be a secondary element. # EPIC Extremity Fusion Plate System # Submitter Information | Applicant: | EPIC Extremity, LLC<br>120 Marguerite Dr., Ste 301<br>Cranberry Twp., PA 16066 | |---------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Contact Person: | Randy Schlemmer<br>EPIC Extremity, LLC<br>120 Marguerite Dr., Ste 301<br>Cranberry Twp., PA 16066<br>(574)248-0060 | | Date Prepared: | October 15th, 2018 | | Name of Device: | EPIC Extremity Fusion Plate System | | Common Name: | Bone Fixation Plate | | Classification Name | Single/Multiple component metallic bone fixation appliances and<br>accessories (per 21 CFR 888.3030) - Class II | | Product Code/Panel: | HRS/Orthopedics | | Predicate Devices: | EPIC Extremity Fracture Plate System (K172441)<br>EPIC Extremity Cannulated Screw System (K153333)<br>Ortholoc 3DI Ankle Fusion Plating System (K121425) Reference<br>Ortholoc 3DI Ankle Fusion Plating System<br>Line Extension (K163650) Reference | ### Indications for Use: The EPIC Extremity Fusion Plate System is indicated for use in stabilization of fresh fractures, revision procedures, joint fusion and reconstruction of small bones of the feet and ankles, including distal tibia. The plates/screws are intended for single use only. ### Device Description The EPIC Extremity Fusion Plate System consists of multiple plate families of various anatomical sizes and shapes, 4.5mm/5.5mm locking and non-locking screws that mate into the plates, 5.5mm fully and partial threaded cancellous, 5.5mm cannulated partial threaded cancellous bone screws as well as various instruments to assist in implanting the system. The EPIC Extremity Fusion Plate System is also designed to be used with various instruments to assist in implanting the system from the previously cleared EPIC Extremity Plate System (K153340). {4}------------------------------------------------ Image /page/4/Picture/1 description: The image shows the logo for EPIC Extremity. The word "EPIC" is written in large, bold, black letters. Below the word "EPIC" is a blue and gray graphic with the word "EXTREMITY" written in smaller, white letters. The logo is simple and modern. # EPIC Extremity Fusion Plate System ### Technological Characteristics The EPIC Extremity Fusion Plate System has the same intended use as the predicate devices. The EPIC Extremity Fusion Plate System has identical indications for use as the predicate devices. The EPIC Extremity Fusion Plate System is manufactured from the same materials as the predicate devices. The EPIC Extremity Fusion Plate System has the following differences from the predicate device: - a. Introduction larger 4.5mm & 5.5mm screw diameters - b. Introduction of cannulated 5.5mm screw diameter - c. Introduction of anatomic specific plate families Any differences between the EPIC Extremity Fusion Plate System and the predicates are considered minor and do not raise questions concerning safety and effectiveness. ## Non-Clinical Performance Data Summary Cross-sectional analysis demonstrated substantial equivalence. Through this analysis it was determined that the addition of the EPIC Extremity Fusion Plates are substantially equivalent in bending strength to the predicate and does not introduce a new worse case into the system. Based on the analysis results and the comparisons provided, the EPIC Extremity Fusion Plate System is considered substantially equivalent to the EPIC Extremity Fracture Plate System (K172441), Ortholoc 3DI Ankle Fusion Plating System (K121425), Ortholoc 3DI Ankle Fusion Plating System Line Extension (K163650) and EPIC Extremity Cannulated Screw System (K153333) in material, construction, size, anatomic location and performance characteristics. # Clinical Performance Data Summary No clinical testing was required. # Non-Clinical and Clinical Performance Data Conclusions Based on the analysis results and the comparisons provided, the EPIC Extremity Fusion Plate System is considered substantially equivalent to the EPIC Extremity Fracture Plate System (K172441), Ortholoc 3DI Ankle Fusion Plating System (K121425), Ortholoc 3DI Ankle Fusion Plating System Line Extension (K163650) and EPIC Extremity Cannulated Screw System (K153333) in material, construction, size, anatomic location and performance characteristics.
Innolitics
510(k) Summary
Decision Summary
Classification Order
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