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510(k) Data Aggregation

    K Number
    K161014

    Validate with FDA (Live)

    Date Cleared
    2016-09-28

    (170 days)

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

    When used as a pedicle screw fixation system, the NuVasive® Reline® System is intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the following acute and chronic instabilities or deformities of the posterior thoracic, lumbar, and sacral spine:

    1. Degenerative disc disease (as defined by back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies)
    2. Degenerative spondylolisthesis with objective evidence of neurologic impairment
    3. Fracture
    4. Dislocation
    5. Scoliosis
    6. Kyphosis
    7. Spinal tumor and/or
    8. Failed previous fusion (pseudoarthrosis)

    When used for posterior non-cervical screw fixation in pediatric patients, NuVasive Reline System implants are indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. Additionally the NuVasive Reline System is intended to treat pediatric patients diagnosed with the following conditions: spondylolysis, and fracture caused by tumor and/or trauma. Pediatric pedicle screw fixation is linited to a posterior approach and is intended to be used with autograft and/or allograft.

    The NuVasive Reline System is also indicated for the treatment of severe spondylolisthesis (Grades 3 and 4) of the L5-S1 vertebral joint in skeletally mature patients receiving fusion by autogenous bone graft, having the device fixed or attached to the lumbar and sacral spine (L3 to sacrum), with removal of the implants after attainment of a solid fusion.

    When used as an anterolateral non-pedicle screw system in the thoracic and lumbar spine, the NuVasive Reline System is also intended for the following indications:

    1. Degenerative disc disease (as defined by back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies)
    2. Spinal stenosis
    3. Spondylolisthesis
    4. Spinal deformities
    5. Fracture
    6. Pseudoarthosis
    7. Tumor resection and/or
    8. Failed previous fusion

    In order to achieve additional levels of fixation, the Reline System rods may be connected to the Armada System.

    Device Description

    The NuVasive Reline System is a pedicle screw system that consists of a variety screws, hooks, rods, lock screws, transverse connectors, rod-to-rod connectors, iliac connectors and associated general instruments. Implant components are available in a variety sizes and can be rigidly locked into a variety of different configurations to suit the individual pathology and anatomical conditions of the patient. This 510(k) is to introduce sterile packaged implants to the Reline System.

    AI/ML Overview

    This document is a 510(k) premarket notification decision letter and summary from the FDA for a medical device (NuVasive Reline System), which is a pedicle screw spinal system.

    The information provided focuses on demonstrating substantial equivalence to predicate devices, rather than on a traditional study with acceptance criteria and performance metrics for a novel AI/software medical device. As such, many of the requested elements for AI/software studies are not applicable or cannot be extracted from this document.

    Here's an attempt to address the questions based on the available information:

    1. A table of acceptance criteria and the reported device performance

    This document does not present acceptance criteria or reported device performance in the manner typically used for software or AI medical devices (e.g., sensitivity, specificity, AUC). Instead, it relies on demonstrating substantial equivalence through design, materials, and function testing for a mechanical implant.

    The performance data mentioned is related to sterilization and packaging validation, which are pass/fail criteria.

    Acceptance Criteria (for the new packaging and sterilization)Reported Device Performance
    Gamma sterilization validatedValidated
    Sterile packaging validatedValidated
    Integrity of sterile barrier over time validatedValidated
    Bacterial endotoxin testing passedPassed

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    Not applicable. The performance data discussed here relates to physical and biological testing of the device and its packaging, not data analysis for an AI or software component. There is no "test set" of patients or data in the context of AI evaluation.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    Not applicable. This is not an AI/software device evaluation.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. This is not an AI/software device evaluation.

    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 implant, not an AI-assisted diagnostic or treatment planning system.

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

    Not applicable. This product is a physical implant, not an algorithm.

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

    For the sterilization and packaging validation, the "ground truth" would be established by standard microbiological and material science testing protocols and industry best practices for medical device sterilization and sterile barrier integrity.

    8. The sample size for the training set

    Not applicable. This is not an AI/machine learning device.

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

    Not applicable.

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