The Impact Medical, LLC screws, plates, and K-Wires are single use, non-sterile and are indicated for use in: - . Fixation and stabilization of fractures in small and long bones; including at a minimum: the tibia, fibula, femoral condyle, pelvis, acetabulum, metacarpals, metatarsals, clavicle, humerus, ulna, middle foot bones, calcaneus and for fixation of fractures in the proximal femur and trochanteric, intertrochanteric, and basilar neck fractures. - . Kirschner (K) wires are used in support of fracture fixation, for ostedtomies in the presence of adequate immobilization and implant guide wires.
Device Story
Orthopedic Fixation Systems (OFS) consist of 316L stainless steel plates, screws (cancellous, cortex, cannulated, locking, headless compression), and K-wires; provided as individual components or sets. Used by surgeons in clinical settings for bone fracture stabilization and fixation. Devices are non-sterile upon receipt; require hospital-validated sterilization prior to use. Single-use only. Performance verified via bench testing including monotonic/cyclic bending, insertion/removal, torsion, pullout, and geometric analysis. Provides mechanical stabilization to facilitate bone healing.
Clinical Evidence
No clinical testing was performed. Substantial equivalence is supported by non-clinical bench testing, including monotonic and cyclic bending tests of plates, insertion/removal, torsion and pullout of screws, and geometric analysis.
Technological Characteristics
Constructed from 316L stainless steel meeting ASTM F138 (UNS S31673). System includes plates, screws (cancellous, cortex, cannulated, locking, headless compression), and K-wires. Mechanical fixation principle. Non-sterile; requires facility-validated sterilization. No software or electronic components.
Indications for Use
Indicated for fixation and stabilization of small and long bone fractures (tibia, fibula, femoral condyle, pelvis, acetabulum, metacarpals, metatarsals, clavicle, humerus, ulna, middle foot bones, calcaneus, proximal femur, trochanteric, intertrochanteric, and basilar neck fractures) and for use of K-wires in fracture fixation support, osteotomies, and as implant guide wires.
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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Image /page/0/Picture/0 description: The image shows the logo for Impact Medical. The word "Impact" is in bold, italicized, black font. To the right of the word "Impact" is a target symbol. To the right of the target symbol is the word "Medical" in bold, black font.
K140216
Pg.1/2
MAY 0 1 2014
# Impact Medical, LLC 510(k) Summary
Date Prepared:
April 29, 2014
### Contact Details
| Applicant Name: | Impact Medical, LLC<br>EJ Duffy, President<br>10110 SW Nimbus Avenue<br>Suite B-6<br>Portland, OR 97223<br>Tel: 503-521-7669<br>Fax: 503-521-7380 |
|-----------------|---------------------------------------------------------------------------------------------------------------------------------------------------|
|-----------------|---------------------------------------------------------------------------------------------------------------------------------------------------|
| <b>Contact Name</b> | Madalyn Duncan |
|---------------------|----------------------------|
| | Regulatory/Quality Contact |
| | 1-503-521-7669 |
### Device Information
| Type of 510(K): | Traditional 510(k) |
|----------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Trade Name: | Orthopedic Fixation Systems (OFS) |
| Device Common Name: | Plates: Fixation Bone<br>Screws: Fixation Bone<br>Wires |
| Device Trade Name: | Orthopedic Fixation Systems (OFS) |
| Product Code (s): | HRS: Plate, Fixation, Bone<br>HWC: Screws, Fixation, Bone<br>HTY: Pin, Fixation, Smooth |
| Classification Regulation: | Title 21 CFR 888.3030: Single/multiple component metallic fixation appliances and accessories<br>Title 21 CFR 888.3040: Smooth or threaded metallic bone fixation fastener |
| Classification: | Class II |
| Classification Panel: | Orthopedics |
### Legally Marketed Predicate Device (s)
510(k)'s: K110086, K962011, K071035, K061620, K000684, K043185, K021556
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K140216
Image /page/1/Picture/2 description: The image shows the logo for Impact Medical. The word "Impact" is in bold, italicized, and black font. To the right of the word "Impact" is a graphic of a target. To the right of the target is the word "Medical" in bold, black font.
### Description
The Impact Medical, LLC Orthopedic Fixation Systems (OFS) consists of various plates, screws and K-Wires that can be provided in sets or individually. Sets are designed for a specific plate and screw combination. They are sold Non-Sterilized by the facility according to a validated and monitored hospital or facility protocol prior to use. All plates, screws and wires are made from 316L stainless steel that meets ASTM F138 Standard Specification for Wrought 18-Chromium-14Nickel-2.5 Molybenum Stainless Steel Bar and Wire for Surgical Implants (UNS S31673) 2008. The screws are in various sizes of Cancellous, Cortex, Cannulated, Locking and Headless Compression. Inclinal, LLC's Orthopedic Fixation System (OFS) of plates, screws and wires are single use only.
#### Intended Use/Indications for Use
The Impact Medical, LLC screws, plates, and K-Wires are single use, non-sterile and are indicated for use in:
- . Fixation and stabilization of fractures in small and long bones; including at a minimum: the tibia, fibula, femoral condyle, pelvis, acetabulum, metacarpals, metatarsals, clavicle, humerus, ulna, middle foot bones, calcaneus and for fixation of fractures in the proximal femur and trochanteric, intertrochanteric, and basilar neck fractures.
- . Kirschner (K) wires are used in support of fracture fixation, for ostedtomies in the presence of adequate immobilization and implant guide wires.
#### Substantial Equivalence Comparison
Impact Medical, LLC Orthopedic Fixation Systems have regulatory classification, similar indications for use, similar performance characteristics, and all systems have the predicates. The devices have been tested in comparison with the predicate and demonstrated to be safe and effective for their intended use.
#### Non-Clinical Performance and Testing
Impact Medical, LLC has confirmed that or hopedic Fixation Systems meet the established requirements and the systems have been tested for compliance with standards in comparison with the predicates. Testing was a combination of Monotonic and cyclic bending tests of plates, insertion/removal, torsion and pullout of screws, and geometric analysis. The product bench and standards comparison testing with the predicated that the devices were safe and effective and substantially equivalent to product already on the market.
#### Clinical Testing
No clinical testing was required nor was performed.
#### Conclusions
Impact Medical, LLC Orthopedic Fixation Systems have intended use, materials and performance characteristics as the predicates. Therefore, Impact Medical, LC believes the systems to be substantially equivalent to the predicates.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES. USA" arranged around the perimeter. Inside the circle is a stylized symbol that resembles an abstract human figure or a caduceus, rendered in a bold, black line.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
May 1, 2014
Impact Medical, LLC Mr. E.J. Duffy Chief Executive Officer 10110 SW Nimbus Avenue, Suite B6 Portland, Oregon 97223
Re: K140216
Trade/Device Name: Orthopedic Fixation Systems (OFS) Regulation Number: 21 CFR 888.3030 Regulation Name: Single/multiple component metallic bone fixation appliances and accessories Regulatory Class: Class II Product Code: HRS, HWC, HTY Dated: April 16, 2014 Received: April 17, 2014
Dear Mr. Duffy:
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. 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 (reporting of medical
{3}------------------------------------------------
Page 2 - Mr. E.J. Duffy
device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR 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/ReportalProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
### Lori A. Wiggins
for
Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known): K 140216
Device Name: Orthopedic Fixation Systems (OFS)
Indications for Use:
The Impact Medical, LLC screws, plates, k-wires and are single use, non-sterile and are indicated for use in:
- fixation and stabilization of fractures in small and long bones; including at a minimum the . tibia , fibula, femoral condyle, pelvis, acetabulum, metacarpals, clavicle, humerus, ulna, middle hand and middle foot bones, calcaneus and for fixation of fractures in the proximal femur and trochanteric, pertrochanteric, intentrochanter ic, and basilar neck fractures
- Kirschner (K) wires are used in support of fracture fixation, for osteotomies in the presence of adequate immobilization and implant guide wires
______________________________________________________________________________________________________________________________________________________________________________ Prescription Use (Part 21 CFR 801 Subpart D)
OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOTWRITE BELOWTHIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
2014.04.29 08:39:14
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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.