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510(k) Data Aggregation

    K Number
    K111370

    Validate with FDA (Live)

    Date Cleared
    2011-09-21

    (128 days)

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

    The ODALYS™ Pedicle Screw System is a pedicle screw system intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine: degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudarthrosis).

    As a pedicle screw system ODALYS™ Pedicle Screw System is indicated for the treatment of severe spondylolisthesis (Grades 3 and 4) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine (13 to sacrum) with removal of the implants after the attainment of a solid fusion.

    Device Description

    The ODALYS™ Pedicle Screw System has been developed with the objective of providing the surgeon with an adaptable fixation system in order to carry out dorsal stabilization of the spine simply, quickly and effectively.

    The system consists of a variety of color coded top loading pedicle screws. The pedicle screws are available in various lengths and diameters. The screw is connected to the rod via a rod connector. Two sizes of connectors are available, short and long. The long is used in cases of spondylolisthesis where the short connector would not be able to engage the rod. The rods are available in multiple lengths.

    Materials: The components are manufactured from titanium alloy (Ti 6Al 4V ELI) per ASTM F136.

    Function: The ODALYS™ Pedicle Screw System is a pedicle screw system intended to provide immobilization and stabilization of spinal segments until fusion takes place.

    AI/ML Overview

    The provided text describes the ODALYS™ Pedicle Screw System, a medical device, and its acceptance criteria as determined by the FDA's 510(k) clearance process.

    Here's an analysis of the acceptance criteria and the "study" (non-clinical tests) used to prove the device meets these criteria:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Implied by Predicate Equivalence)Reported Device Performance (ODALYS™ Pedicle Screw System)
    Mechanical Performance (Static Compression Resistance)Met or exceeded the performance of predicate devices: Moss Miami (K000536) and PWB Lumbosacral Spine System (K920116) as evidenced by ASTM F1717 testing.
    Mechanical Performance (Dynamic Compression Resistance)Met or exceeded the performance of predicate devices: Moss Miami (K000536) and PWB Lumbosacral Spine System (K920116) as evidenced by ASTM F1717 testing.
    Mechanical Performance (Static Torsion Resistance)Met or exceeded the performance of predicate devices: Moss Miami (K000536) and PWB Lumbosacral Spine System (K920116) as evidenced by ASTM F1717 testing.
    Material CompositionThe device is manufactured from titanium alloy (Ti 6Al 4V ELI) per ASTM F136, which is equivalent to materials used in predicate devices.
    Intended Use (Immobilization and stabilization of spinal segments for fusion)The ODALYS™ Pedicle Screw System is intended for immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion for specific conditions (degenerative spondylolisthesis, fracture, dislocation, scoliosis, kyphosis, spinal tumor, failed previous fusion), and for severe spondylolisthesis (Grades 3 and 4) of L5-S1. This matches the intended use of predicate devices.
    Design and Function (Top-loading pedicle screws, rod connectors, rods to provide spinal stabilization)The ODALYS™ Pedicle Screw System has a similar design (variety of color-coded top-loading pedicle screws, rod connectors, and rods) and function (immobilization and stabilization of spinal segments until fusion takes place) compared to predicate devices.

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size: The document does not specify a "test set" in the context of human data. The testing performed was non-clinical, involving mechanical tests of the device. The sample size for these mechanical tests (e.g., number of screws or constructs tested for each configuration) is not provided in the summary.
    • Data Provenance: The data provenance is from non-clinical laboratory testing (mechanical testing per ASTM standards). There is no information regarding country of origin or whether it's retrospective or prospective, as it pertains to physical device testing, not human data.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    This section is not applicable. The "ground truth" for this device, in the context of the 510(k) submission, is its mechanical performance and material properties. This is established by adherence to recognized ASTM standards for medical devices, rather than expert consensus on a dataset. The results are compared to predicate devices.

    4. Adjudication Method for the Test Set

    This section is not applicable. There was no human "test set" requiring adjudication. The assessment was based on objective mechanical testing results comparing the device to accepted standards and predicate device performance.

    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

    No, a Multi-Reader, Multi-Case (MRMC) comparative effectiveness study was not conducted. This type of study is relevant for diagnostic or AI-assisted devices that involve human interpretation of medical images or data. The ODALYS™ Pedicle Screw System is a physical implant, not an AI-based diagnostic tool.

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

    No, a standalone algorithm performance study was not done. The device is a physical implant; there is no AI algorithm associated with it.

    7. The Type of Ground Truth Used

    The "ground truth" for this device's acceptance is based on:

    • Compliance with recognized industry standards (ASTM F1717 and ASTM F136).
    • Substantial equivalence to legally marketed predicate devices in terms of intended use, design, materials, and function, as demonstrated by meeting or exceeding the mechanical performance and material specifications of those predicates.

    8. The Sample Size for the Training Set

    This section is not applicable. The ODALYS™ Pedicle Screw System is a physical pedicle screw system, not an AI or machine learning device that requires a "training set."

    9. How the Ground Truth for the Training Set was Established

    This section is not applicable for the same reason as point 8. There is no training set for this device.

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