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510(k) Data Aggregation

    K Number
    K130176

    Validate with FDA (Live)

    Manufacturer
    Date Cleared
    2013-03-28

    (62 days)

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

    The Firebird Spinal Fixation System is intended for posterior, noncervical pedicle fixation. Pedicle screw fixation is limited to skeletally mature patients and is intended to be used as an adjunct to fusion using autograft or allograft. The device is indicated for all of the following indications:
    a) degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies)
    b) spondylolisthesis,
    c) trauma (i.e., fracture or dislocation),
    d) spinal stenosis,
    e) deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis),
    f) tumor,
    g) pseudoarthrosis, and
    h) failed previous fusion
    The Phoenix MIS Fixation System when used with the Firebird Spinal Fixation System is indicated to provide the surgeon with a minimally invasive approach for posterior spinal surgery.
    The Firebird Spinal Fixation System components are used with certain components of the Orthofix Spinal Fixation System, including rods, rod connectors and cross-connectors.

    Device Description

    The Firebird Spinal Fixation System is a temporary, multiple component system comprised of a variety of non-sterile, single use components, made of titanium alloy or cobalt chrome alloy, that allow the surgeon to build a spinal implant construct. The system is attached to the vertebral body bv means of screw . fixation to the non-cervical spine. The Firebird Spinal Fixation System consists of an assortment of pedicle screws, set screws, lateral offsets, bone screws and screw bodies. The Firebird Spinal Fixation System implants are not compatible with components or metal from any other manufacturer's system.
    The Phoenix MIS Fixation System when used with the Firebird Spinal Fixation System as indicated to provide the surgeon with a minimally invasive approach for posterior spinal surgery.
    The Firebird Spinal Fixation System components are used with certain components of the Orthofix Spinal Fixation System, including rods, rod connectors and cross-connectors.

    AI/ML Overview

    The Orthofix Firebird Spinal Fixation System is a Class III preamendment device (Pedicle screw spinal system, 21 CFR 888.3070) designed for posterior, non-cervical pedicle fixation as an adjunct to fusion.

    Here's an analysis of the acceptance criteria and supporting evidence:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance CriterionReported Device PerformanceStudy Type
    Substantial Equivalence (Overall Safety and Effectiveness)"The Firebird Spinal Fixation System were shown to be substantially equivalent to previously cleared devices with respect to intended use, design, function, materials, and performance."Special K130176 Summary
    Mechanical Performance (Rod Connectors)"The Orthofix Firebird Spinal Fixation System proposed rod connectors are substantially equivalent to the predicate devices based on axial grip and torque verification, FEA simulation, and material characterization."Mechanical Testing, FEA Simulation, Material Characterization (detailed results not provided in summary)
    Material Compatibility"Titanium alloy per ASTM F136 and Cobalt-Chrome per ASTM F1537."Material Specification/Testing

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

    The provided 510(k) summary does not specify sample sizes for mechanical testing or FEA simulations, nor does it indicate the provenance of any data beyond general material specifications. This submission is for a Special 510(k), which typically relies heavily on comparison to a predicate device and may not require extensive new testing if modifications are minor and proven equivalent.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    This 510(k) summary is for a spinal fixation system, not an AI or imaging device that would typically involve human expert ground truth establishment for diagnostic accuracy. Therefore, this information is not applicable and not provided.

    4. Adjudication Method for the Test Set

    As this is not an AI or imaging device requiring human expert review for diagnostic accuracy, an adjudication method is not applicable and not provided.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No, an MRMC comparative effectiveness study was not done. This type of study is typically for diagnostic imaging devices where human interpretation is a key component, often with and without AI assistance. This device is a surgical implant.

    6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done

    No, a standalone performance study (algorithm only) was not done. This is not an AI-driven device. The "performance" assessment refers to the mechanical and material characteristics of the implant itself, not an algorithm's output.

    7. The Type of Ground Truth Used

    For this device, the "ground truth" is established through:

    • Material Specifications: Adherence to established ASTM standards (ASTM F136 for titanium alloy and ASTM F1537 for cobalt-chrome).
    • Mechanical Performance Standards: Verification against established industry standards or predicate device performance for axial grip and torque.
    • Engineering Principles: Finite Element Analysis (FEA) simulation.

    8. The Sample Size for the Training Set

    This is not applicable. This submission concerns a physical medical device (spinal implant), not an AI algorithm that requires a training set.

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

    This is not applicable as there is no AI training set for this device.

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