ABCcolla® Bone Graft is an implant intended to fill bony voids or gaps of the skeletal system (i.e., extremities and pelvis). These osseous defects are surgically created or the result of traumatic injury to the bone and are not intrinsic to the stability of the bony structure. ABCcolla® Bone Graft resorbs and is replaced with bone during the healing process.
Device Story
ABCcolla® Bone Graft is a porcine-derived bone mineral matrix; functions as a resorbable bone void filler. Implanted by surgeons into skeletal voids or gaps (extremities/pelvis) not requiring structural stability. Device resorbs over time, facilitating replacement with natural bone during healing. Supplied in granule and cube shapes; sterilized via gamma-irradiation. Intended for single-use clinical application.
Clinical Evidence
No human clinical data. Evidence includes bench testing: chemical composition (XRD, ICP/MS), morphology/pore size (SEM), porosity (mercury intrusion), density, and moisture content. Biocompatibility testing per ISO 10993 series (parts 1, 3, 4, 5, 6, 10, 11). Sterilization validated per ISO 11137. Shelf-life evaluated via real-time aging. Pyrogenicity assessed via LAL method. Pre-clinical animal performance testing conducted using a critical-size bone defect model to evaluate new bone formation.
Technological Characteristics
Porcine-derived bone mineral matrix; hydroxyapatite composition. Supplied as granules or cubes. Sterilized via gamma-irradiation (ISO 11137). Characterized by Ca/P ratio, pore size, and porosity. Non-software device.
Indications for Use
Indicated for patients requiring filling of bony voids or gaps in the skeletal system (extremities and pelvis) that are not intrinsic to the stability of the bony structure, resulting from surgical creation or traumatic injury.
Regulatory Classification
Identification
A resorbable calcium salt bone void filler device is a resorbable implant intended to fill bony voids or gaps of the extremities, spine, and pelvis that are caused by trauma or surgery and are not intrinsic to the stability of the bony structure.
Special Controls
*Classification.* Class II (special controls). The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance: Resorbable Calcium Salt Bone Void Filler Device; Guidance for Industry and FDA.” See § 888.1(e) of this chapter for the availability of this guidance.
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February 1, 2018
ACRO Biomedical Co., Ltd. Dar-Jen Hsieh Chief Executive Officer 3F, No. 57, Luke 2nd Road, Lujhu District Kaohsiung City 82151 TAIWAN
Re: K171629
Trade/Device Name: ABCcolla® Bone Graft Regulation Number: 21 CFR 888.3045 Regulation Name: Resorbable calcium salt bone void filler device Regulatory Class: Class II Product Code: MOV Dated: January 10, 2018 Received: January 10, 2018
Dear Dar-Jen Hsieh:
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 of medical device-related adverse events) (21 CFR 803); good
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manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); 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 the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
For comprehensive regulatory information about medical devices and radiation-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,
## Katherine D. Kavlock -S
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 Statement
510(K) Number (If Known): __K171629
Device Name: ABCcolla® Bone Graft
Indications for Use: ABCcolla® Bone Graft is an implant intended to fill bony voids or gaps of the skeletal system (i.e., extremities and These osseous defects are surgically created or the pelvis). result of traumatic injury to the bone and are not intrinsic to the stability of the bony structure. ABCcolla® Bone Graft resorbs and is replaced with bone during the healing process.
Prescription Use (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH Office of Device Evaluation (ODE)
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## 510(k) Summary
This summary of 510(k) Safety and Effectiveness information is being submitted in accordance with the requirements of Safe Medical Device Act (SMDA) of 1990 and Title 21 CFR 807.92. The assigned 510(k) number is_________________________________________________________________________________________________________________________________________________
| Applicant | ACRO Biomedical Co., Ltd. |
|--------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | 3rd Fl., No.57, Luke 2nd Rd., Lujhu Dist., Kaohsiung City 82151 |
| | Taiwan |
| | Telephone: +886-7-6955-569 |
| | Fax: +886-7-6955-069 |
| Contact Person | DAR-JEN HSIEH |
| | CEO |
| | E mail: dj@acrobiomedical.com |
| Date of Summary | May 1st, 2017 |
| Name of Device | ABCcolla® Bone Graft |
| Common Name | Resorbable Bone Void Filler |
| Classification | Class II |
| Regulation Number | 21 CFR 888.3045 |
| Product Code | MQV |
| Advisory Panel | ORTHOPEDIC DEVICES |
| Predicate Device | • ORTHOSS® Resorbable Bone Void Filler, K090401<br>Ed. Geistlich Soehne Ag Für Chemische Industrie<br>• Bicera™ Resorbable Bone Substitute, K110949<br>Wiltrom Corporation Limited |
| Reference Device | · Geistlich Bio-Oss®, K122894<br>Geistlich Pharma Ag |
| Device Description | ABCcolla® Bone Graft is a bone mineral matrix of porcine origin.<br>ABCcolla® Bone Graft is physically and chemically comparable to<br>the mineralized matrix of human bone. |
| Intended Use | ABCcolla® Bone Graft is an implant intended to fill bony voids or<br>gaps of the skeletal system (i.e., extremities and pelvis). These<br>osseous defects are surgically created or the result of traumatic<br>injury to the bone and are not intrinsic to the stability of the bony<br>structure. ABCcolla® Bone Graft resorbs and is replaced with bone<br>during the healing process. |
| Technological | ABCcolla® Bone Graft has been designed and manufactured to be |
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Characteristics substantially equivalent to predicate and reference device through comparison in areas including intended use, material origin, physical structure, chemical characteristics (hydroxyapatite, Ca/P ratio), principles of operation and design (user, how supplied, single use, gamma-irradiation sterilization).
ABCcolla® Bone Graft was designed in granule and cube shape similar to the predicate and reference device with different particle size which is between in the maximum and minimum size of the predicate device.
The performance of ABCcolla® Bone Graft, including chemical Performance Data composition, physical properties, biocompatibility, sterilization, packing, shelf-life, pyrogenicity and pre-clinical animal performance testing were performed to demonstrate substantial equivalence to the predicate devices.
> Chemical composition (hydroxyapatite, Ca/P ratio) was analyzed via X-ray diffraction (XRD), trace element analysis was performed by inductively coupled plasma/mass spectroscopy (ICP/ MS), particle pore size and morphology was evaluated via scanning
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electron microscopy (SEM), porosity was determined by mercury intrusion porosimetry, density was evaluated via tap density analyzer, and moisture content was determined by moisture analyzer.
Biocompatibility studies were performed in accordance with ISO 10993-1, ISO10993-3, ISO10993-4, ISO 10993-5, ISO 10993-6, ISO 10993-10 and ISO10993-11. ABCcolla® Bone Graft was sterilized by gamma-irradiation and the process was validated in accordance with ISO 11137. ABCcolla® Bone Graft also has been tested for its packing integrity. The product shelf-life was evaluated in real-time aging study with passing results. Pyrogenicity was assessed with limulus amebocyte lysate (LAL) method and met the limits of established guidelines.
According to Class II Special Controls Guidance Document: Resorbable Calcium Salt Bone Void Filler Device, critical-size bone defect model was performed to evaluated the new bone formation and healing effect of ABCcolla® Bone Graft in pre-clinical animal performance testing.
Substantial ABCcolla® Bone Graft is substantially equivalent to the predicate Equivalence device with respect to functionality, design, materials, sterilized Summary method, package material, intended use and performance characteristics.
Conclusion Based on the 510(k) summaries and the information provided herein, we conclude that ABCcolla® Bone Graft is substantially equivalent to the predicate device under the Federal Food, Drug, and Cosmetic Act.
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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.
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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?
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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.
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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.
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Reading rule for every project: how many summaries do you read in full?
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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.
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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.
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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.
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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.