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510(k) Data Aggregation

    K Number
    K080075

    Validate with FDA (Live)

    Date Cleared
    2008-01-28

    (17 days)

    Product Code
    Regulation Number
    888.3070
    Age Range
    All
    Reference & Predicate Devices
    N/A
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticPediatricDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Vertefix® Pedicle Screw Spinal System is intended for posterior, non cervical pedicle fixation in skeletally mature patients receiving fusion by autogenous bone graft in the thoracolumbar spine for the following indications: Spondylolisthesis, Trauma (e.g.fracture or dislocation), Spinal stenosis, deformities or curvatures (scoliosis, kyphosis or lordosis), tumor, pseudoarthrosis, and failed previous fusion.
    Removal of the implants after the attainment of a solid fusion is optional.

    Device Description

    The Vertefix® Pedicle Screw Spinal System is a multiple component, posterior spinal fixation system which consists of pedicle screws, rods, set screws, connectors, hooks, and a transverse (cross) linking mechanism.
    The Vertefix® Pedicle Screw Spinal System will allow surgeons to build a spinal implant construct to stabilize and promote spinal fusion. The Vertefix® Pedicle Screw Spinal System components are supplied non-sterile, and are single use.

    AI/ML Overview

    This document describes a 510(k) premarket notification for the Vertefix® Pedicle Screw Spinal System, seeking to demonstrate substantial equivalence to a predicate device. As such, the study design focuses on comparative performance against the predicate rather than establishing novel acceptance criteria and reporting performance for an AI-powered device.

    Therefore, many of the typical questions for AI acceptance criteria and studies (like sample sizes for test/training sets, expert ground truth, MRMC studies, standalone performance, etc.) are not applicable to this type of submission.

    Here's an attempt to address the relevant points based on the provided text, and explicitly state when information is not available or not applicable:


    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySpecific CriteriaReported Device PerformanceComments
    Mechanical PerformanceSubstantial Equivalence to Predicate Device for Construct Testing (ASTM F1717)"This testing demonstrated substantial equivalence to the predicate systems and other marketed systems."Original Vertefix system met this. For the modified system (5.5mm rod), specific testing was not repeated because the change was expected to improve performance, but thread pullout testing was performed.
    Material PropertiesConformance to ASTM F136 for Titanium alloy (Ti-6Al-4V ELI)"The Vertefix® Spinal System components are fabricated from Titanium alloy (Ti-6Al-4V ELI) that conforms to ASTM F136."This ensures material safety and performance.
    Design and FunctionSubstantial Equivalence to Predicate Device in terms of intended use, operating principle, and design."Further comparison to the predicates also demonstrated substantial equivalence in terms of intended use, operating principle, materials, shelf life and design."Confirms fundamental similarity to existing, approved devices.
    Thread Design StrengthAdequate pullout strength (no specific numerical criteria given)"Thread pullout testing was however performed to prove the thread design."This was done for the modified system with the 5.5mm rod.
    Safety and EffectivenessNo significant differences that would adversely affect product use compared to predicate."There are no significant differences between the Vertefix® Pedicle Screw Spinal System and the approved Vertefix® Pedicle Screw Spinal System or other spinal fixation systems currently being marketed, which would adversely affect the use of the product."This is the overarching criterion for 510(k) substantial equivalence.

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

    • Not Applicable / Not Provided. This is a mechanical device, not an AI/software device that uses "data" in the typical sense for a test set. The "testing" referred to is mechanical testing of physical components (e.g., construct testing per ASTM F1717, thread pullout testing). The sample size for these mechanical tests is not specified in the provided text.

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

    • Not Applicable. Ground truth in the context of an AI device typically refers to clinical diagnosis or outcome verified by experts. For a mechanical implant device, the "ground truth" is defined by established engineering standards (like ASTM F1717) and successful performance in those tests. Expert consensus for clinical diagnosis is not relevant here.

    4. Adjudication method for the test set

    • Not Applicable. Adjudication methods are relevant for subjective interpretations of data, particularly in clinical assessments where multiple readers might disagree. For mechanical testing against objective standards, adjudication is not a standard practice.

    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 mechanical spinal implant system, not a diagnostic or prognostic AI tool that would assist human readers.

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

    • Not Applicable. This is a mechanical device. There is no algorithm.

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

    • The "ground truth" for this device's performance is established by conformance to recognized industry standards (e.g., ASTM F1717) for mechanical testing and the material specifications (ASTM F136). The equivalence to a predicate device, which has already established safety and efficacy through its own testing and clinical use, serves as the primary benchmark.

    8. The sample size for the training set

    • Not Applicable / Not Provided. As a mechanical device, there is no "training set" in the computational sense. The design and testing are based on engineering principles and performance standards, not machine learning.

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

    • Not Applicable. There is no training set for this type of device.

    Summary of the Study that Proves the Device Meets Acceptance Criteria:

    The study that proves the Vertefix® Pedicle Screw Spinal System meets its acceptance criteria is primarily a bench-top mechanical evaluation demonstrating substantial equivalence to a legally marketed predicate device.

    1. Original System Testing: The original Vertefix® Pedicle Screw Spinal System underwent construct testing according to ASTM F1717. This testing demonstrated "substantial equivalence to the predicate systems and other marketed systems" in terms of mechanical performance.
    2. Material Conformance: The components are fabricated from Titanium alloy (Ti-6Al-4V ELI) conforming to ASTM F136, which establishes material quality and safety.
    3. Modified System Justification: For the modified system (with a 5.5mm rod), a full re-test against ASTM F1717 was not performed. The rationale provided was that this change was expected to "perform slightly better than the already tested Vertefix Spinal System." However, thread pullout testing was performed specifically to "prove the thread design" of the modified system.
    4. Comparative Analysis: A comparative analysis against various predicates (including the original Vertefix system) was performed, concluding that there are "no significant differences... which would adversely affect the use of the product" in terms of design, function, materials, operational principles, and intended use.

    In essence, the "study" for this 510(k) submission is a combination of prior mechanical testing, material standardization, and a reasoned argument supported by specific additional testing (thread pullout) and comparative analysis to demonstrate that the new device is as safe and effective as a legally marketed predicate.

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