K243491 · Stryker Leibinger GmbH & Co KG · HRS · Dec 11, 2024 · Orthopedic
Device Facts
Record ID
K243491
Device Name
SternalPlate Expansion
Applicant
Stryker Leibinger GmbH & Co KG
Product Code
HRS · Orthopedic
Decision Date
Dec 11, 2024
Decision
SESE
Submission Type
Special
Regulation
21 CFR 888.3030
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The SternalPlate System is indicated for use in stabilization and fixation of fractures of the anterior chest wall including sternal fixation following sternotomy, sternal fracture(s), and sternal reconstructive surgical procedures to promote bony fusion.
Device Story
SternalPlate Expansion consists of four additional bone plate variants (T-Plates and Transverse Plates) for the existing SternalPlate System. Device functions as internal fixation for anterior chest wall stabilization; plates are secured to bone to promote fusion. Used in surgical settings by surgeons; provides mechanical support to sternum and ribs. Output is physical stabilization of bone segments. Benefits include restored chest wall integrity and support for bony healing. Modifications involve geometric variations of previously cleared plates; materials, manufacturing, and fundamental scientific technology remain unchanged.
Clinical Evidence
No clinical data. Bench testing only. Verification and validation testing confirmed plate strength and stiffness met acceptance criteria compared to predicate devices. Biocompatibility evaluated per ISO 10993-1:2018.
Technological Characteristics
Metallic bone fixation plates (T-Plates and Transverse Plates). Materials, tolerances, and manufacturing processes are identical to previously cleared Stryker SternalPlate System (K183172). Mechanical fixation principle. No software or energy source.
Indications for Use
Indicated for patients requiring stabilization and fixation of anterior chest wall fractures, including sternal fixation post-sternotomy, sternal fractures, and sternal reconstructive procedures to promote bony fusion.
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.
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December 11, 2024
Stryker Leibinger GmbH & Co. KG Amelia Kesti Staff Regulatory Affairs Specialist Boetzinger Strasse 41 Freiburg, D-79111 Germany
Re: K243491
Trade/Device Name: SternalPlate Expansion 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: November 8, 2024 Received: November 12, 2024
Dear Amelia Kesti:
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 (the 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 available at https://www.accessdata.fda.gov/scripts/cdrh/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.
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Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatory
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assistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
# CHRISTOPHER FERREIRA -S
Christopher Ferreira, MS Assistant Director DHT6C: Division of Restorative, Repair and Trauma Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
Submission Number (if known)
K243491
Device Name
SternalPlate Expansion
## Indications for Use (Describe)
The SternalPlate System is indicated for use in stabilization of fractures of the anterior chest wall including sternal fixation following sternal fracture(s), and sternal reconstructive surgical procedures to promote bony fusion.
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)
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# 510(k) Summary
This section provides a summary of 510(k) information in accordance with the requirements of 21 CFR 807.92.
- SUBMITTER [§807.92(a)(1)] I.
| 510(k) Owner: | Stryker Leibinger GmbH & Co. KG |
|---------------|---------------------------------|
| | Boetzinger Strasse 41 |
| | D-79111 Freiburg, Germany |
- Submitter/ Contact Amelia Kesti Person: Staff Regulatory Affairs Specialist Stryker Craniomaxillofacial (CMF) 1941 Stryker Way Portage, MI 49002
Phone: 269-330-5919
Date prepared: 11/08/2024
### II. DEVICE [§807.92(a)(2)]
| Trade Name: | SternalPlate Expansion |
|------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------|
| Abbreviated Name: | SternalPlate Expansion |
| Common or Usual Name: | Plate, Fixation, Bone |
| Device: | SternalPlate Expansion |
| Classification Name &<br>Regulation Description: | Plate, Fixation, Bone; per 21 CFR §888.3030 |
| Regulation Medical<br>Specialty & Review Panel: | Office of Product Evaluation and Quality, Office of<br>Orthopedic Devices, Division of Restorative, Repair and<br>Trauma, Devices, DHT6C |
| Product Code: | HRS |
| Regulatory Device Class: | Class II |
| *Note the company Stryker or legacy name Stryker Leibinger precedes the product/trade name and<br>predicate device in some documentation | |
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#### III. PREDICATE DEVICE [§807.92(a)(3)]
- A. Predicate Devices: The predicate devices for this Special 510(k) are:
- 1. Primary Predicate: Stryker SternalPlate System K183172
- i. Submission Branch of Predicate Device- Division of Orthopedic Devices, Office of Device Evaluation, Center for Devices and Radiological Health
- 2. Additional Predicate: DePuy Synthes Sternal Fixation System K190963
- Branch of Predicate Device- Division of i. Submission Restorative, Repair and Trauma Devices, Office of Orthopedic Devices, office of Product Evaluation and Quality, Center for Devices and Radiological Health
- 3. Additional Predicate: KLS Martin Thoracic Plating System -K153482
- i. Submission Branch of Predicate Device- Division of Orthopedic Devices, Office of Device Evaluation, Center for Devices and Radiological Health
# IV. DEVICE DESCRIPTION [§807.92(a)(4)]
- A. Submission Branch of Subject Device: Office of Orthopedic Devices, Office of Product Evaluation and Quality, Division of Stereotaxic, Trauma, and Restorative Devices, DHT6C
- B. Subject Device: SternalPlate Expansion
This Special 510(k) is submitted to evaluate the modifications to the Predicate Device plates resulting in the Subject Device plates. There have been no changes to the previously cleared plates and screws cleared in K183172, this submission is only for the addition of the four new Subject Device plates.
### INDICATIONS FOR USE [§807.92(a)(5)] V.
The Predicate and Subject devices are both intended for use in the anterior chest wall. The anterior chest wall includes both the sternum and the anterior ribs. The Subject Device does not change the existing indications for use for the Stryker SternalPlate System. The new plates fall within the scope of the existing indications in the anterior chest wall without alteration.
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## TABLE 5-1: COMPARISON OF INDICATIONS FOR USE
| Aspect | Subject Device | Primary Predicate Device (K183172) |
|----------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended<br>Use/Indications for<br>Use | The SternalPlate System is indicated for use in stabilization<br>and fixation of fractures of the anterior chest wall including<br>sternal fixation following sternotomy, sternal fracture(s), and<br>sternal reconstructive surgical procedures to promote bony<br>fusion. | The SternalPlate System is indicated for use in stabilization and<br>fixation of fractures of the anterior chest wall including sternal<br>fixation following sternotomy, sternal fracture(s), and sternal<br>reconstructive surgical procedures to promote bony fusion. |
Please note that this 510(k) lists several additional Predicate devices, however, these additional Predicate devices were used for testing and not verall substantial equivalence evaluation.
# COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE [§807.92(a)(6)]
The Subject Device is compared to its Predicate Devices for substantial equivalence of technological characteristics based on the following criteria:
- A. Principles of Operation
- B. Technological Characteristics
# A. Principles of Operation / Operating Principle
The basic operating principle of the Subject Device remains the same as the Predicate Device. The basic operating principle of the Subject Device, as well as the Predicate Device is fixation and stabilization of the anterior chest wall. The method of site preparation and fixation is the same for both the Subject and Predicate Device. The fundamental scientific technology of the Subject Device has not changed. This is because the principle of operation, the mechanism of action, the intended use, and the materials of construction have not changed as a result of the device modifications.
# B. Technological Characteristics
There have been no changes to the previously cleared plates and screws cleared in K183172, this Special 510(k) is only for the addition of the four new Subject Device plates. The four Subject Device plates include T-Plates and Transverse Plates. Both Subject Device variants, the T-Plates and Transverse Plates, are geometrically derived from the following Predicate Device plates: the Ladder Plate Narrow (Reff/ 4740006) and the Straight 24-hole Plate (Ref# 4740012).
The Subject Device plates therefore have the same features, the same tolerances, and are made from the same material as the Predicate Device plates. Furthermore, the Subject
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Device plates are manufactured with the same manufacturing process as the Predicate Device plates.
#### VI. PERFORMANCE DATA [§807.92(b)(7)]
Appropriate strength and stiffness of the new plates are confirmed by the Verification and Validation testing, and no new questions of safety or effectiveness arise as a result of the testing.
The subject devices have been evaluated for Biocompatibility per the requirements of ISO 10993-1:2018 and in alignment with corresponding FDA guidance. This evaluation has concluded that no new or increased biocompatibility risks are associated with the subject device.
Sterility testing was not required as a basis for substantial equivalence. There is no change in the subject device material, manufacturing process, duration or location of contact, or reprocessing methods.
# Performance Bench Testing
As the Subject Device plates, unlike the original Predicate Device plates, can be fixated laterally to the sternum, additional Verification and Validation data was needed for the Subject Device. This submission uses well established test methods used in prior submissions including K183172 previously reviewed by the FDA. These tests are summarized within the Special 510(k).
Plate stiffness and strength were tested in comparison to the Additional Predicate Devices DePuy Synthes Sternal Fixation System (K190963) and KLS Martin Thoracic Plating System (K153482). The Subject Device plates met all acceptance criteria as compared to the Additional Predicate Devices. The results of this testing show that the Subject Device plates do not raise new questions in terms of safety and effectiveness when compared to the Predicate Device plates.
## Animal Testing
Animal testing was not required as a basis for substantial equivalence.
# Clinical Testing [§807.92(b)(2)]
Clinical testing was not required as a basis for substantial equivalence.
## VII. CONCLUSIONS [§807.92(b)(3)]
In summary, the Subject Device is substantially equivalent to its Predicate Device. The Subject Device's features, tolerances, material, mechanism of action, intended use, and
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manufacturing process are the same as the Predicate Device. The Subject Device's intended use is unchanged compared to the Predicate Device. Appropriate strength and stiffness of the new plates are confirmed by the Verification and Validation testing, and no new questions of safety or effectiveness arise as a result of the testing. There are no new questions of safety or effectiveness regarding the modifications to the Predicate Device plates resulting in the four Subject Device plates. According to the comparison based on the requirements of 21 CFR 807.87 and the information provided herein, it is concluded that the information included in this submission supports substantial equivalence to the predicate devices.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.