(29 days)
The CROSSWAY™ Spinal Access System is indicated for minimally invasive visualization and access to the anterior spine for assisting in various surgical procedures such as herniated disc repair, biopsy, or harvesting autogenous bone.
The CROSSWAY™ Spinal Access System consists of instruments used for minimally invasive visualization and access to the anterior spine. The system includes various guides, sleeves, temporary fixation screws, drills, and general surgical instruments.
Here's an analysis of the provided text regarding the CROSSWAY™ Spinal Access System, focusing on acceptance criteria and study details.
1. Table of Acceptance Criteria and Reported Device Performance
Based on the provided text, the submission focuses on demonstrating substantial equivalence to predicate devices rather than establishing novel safety and effectiveness through extensive clinical trials with specific acceptance criteria. The performance data presented is primarily related to design verification and material testing.
| Acceptance Criteria Category | Reported Device Performance |
|---|---|
| Design/Dimensional Analysis | Specification review and dimensional analysis demonstrate that the CROSSWAY™ instruments can be used in accordance with their indications. |
| Bacterial Endotoxin Testing (BET) | Bacterial endotoxin testing (BET) was conducted in accordance with ANSI/AAMI ST-72:2011. (Implied to have met the standard) |
| Biocompatibility | Biocompatibility of patient-contacting materials was demonstrated by using materials that meet applicable standards or are used in 510(k) cleared devices. (Implied to be acceptable) |
| Technological Characteristics (Comparison to Predicate) | Subject CROSSWAY™ instruments have similar technological characteristics with minor modifications compared to predicate CROSSWAY™ instruments including design, intended use, material composition, function, and range of sizes. (Implied to be substantially equivalent) |
2. Sample Size Used for the Test Set and Data Provenance
The provided document does not mention a traditional "test set" in the context of clinical performance or algorithm evaluation. The studies mentioned are primarily engineering and material testing.
- Design/Dimensional Analysis: The "sample size" would refer to the specific instruments and components of the CROSSWAY™ system that underwent review and analysis. The document does not specify this number.
- Bacterial Endotoxin Testing: The sample size would be the number of devices or material samples tested for endotoxin. This is not specified.
- Biocompatibility: The sample size would relate to the materials tested. This is not specified.
Data Provenance: Not applicable as there are no clinical test sets or patient data mentioned. The data provenance is from internal testing and material certification.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This information is not applicable as the provided document does not describe a study involving human expert evaluation of a test set (e.g., for image interpretation or diagnosis). The studies are engineering and materials-based.
4. Adjudication Method for the Test Set
This information is not applicable as there is no traditional "test set" requiring expert adjudication for ground truth.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No, an MRMC comparative effectiveness study was not done or mentioned in this document. This submission is for a medical instrument system, not a diagnostic or AI-assisted interpretation device. Therefore, there's no mention of human readers improving with or without AI assistance.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
No, a standalone algorithm performance study was not done or mentioned. The CROSSWAY™ Spinal Access System is a set of physical surgical instruments, not an algorithm or AI system.
7. Type of Ground Truth Used
The concept of "ground truth" as typically applied to diagnostic or AI studies is not directly relevant here. For the studies mentioned:
- Design/Dimensional Analysis: The "ground truth" is adherence to engineering specifications and design tolerances.
- Bacterial Endotoxin Testing: The "ground truth" is compliance with the specified standard (ANSI/AAMI ST-72:2011) and its biological limits.
- Biocompatibility: The "ground truth" is that the materials either meet applicable standards or have been previously cleared for patient contact in other 510(k) devices.
8. Sample Size for the Training Set
This information is not applicable as the CROSSWAY™ Spinal Access System is a set of surgical instruments, not an AI or machine learning device that requires a training set.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable for the same reasons as point 8.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
Globus Medical Inc. Kelly J. Baker, Ph.D. Senior Vice President, Regulatory and Clinical Affairs 2560 General Armistead Avenue Audubon, Pennsylvania 19403
Re: K190598
Trade/Device Name: CROSSWAY™ Spinal Access System Regulation Number: 21 CFR 888.1100 Regulation Name: Arthroscope Regulatory Class: Class II Product Code: HRX Dated: March 6, 2019 Received: March 7, 2019
Dear Dr. Baker:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm_identifies_combination product submissions. 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
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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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, ff 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 comprehensive regulatory information about mediation-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@tda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
For Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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510(k) Summary: CROSSWAY™ Spinal Access System
Company: Globus Medical Inc. 2560 General Armistead Ave. Audubon, PA 19403 610-930-1800
- Contact: Kelly J. Baker, Ph.D. Senior Vice President, Regulatory and Clinical Affairs
- March 6, 2019 Date Prepared:
Device Name: CROSSWAY™ Spinal Access System
- Common Name: Rigid Endoscope and Instrument Set
- Classification: Per 21 CFR as follows: §888.1100 Arthroscope Product Code: HRX Requlatory Class: II, Panel Code: 87
Primary Predicate: TransCorp Spinal Access System (K113352)
Reference Device: HAVEN Laminoplasty System (K171413) QUARTEX Spinal System (K161591)
Purpose:
The purpose of this submission is to request clearance for sterile and modified CROSSWAY™ instruments.
Device Description:
The CROSSWAY™ Spinal Access System consists of instruments used for minimally invasive visualization and access to the anterior spine. The system includes various guides, sleeves, temporary fixation screws, drills, and general surgical instruments.
Indications for Use:
The CROSSWAY™ Spinal Access System is indicated for minimally invasive visualization and access to the anterior spine for assisting in various surgical procedures such as herniated disc repair, biopsy, or harvesting autogenous bone.
Performance Data:
Specification review and dimensional analysis demonstrate that the CROSSWAY™ instruments can be used in accordance with their indications.
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Bacterial endotoxin testing (BET) was conducted in accordance with ANSI/AAMI ST-72:2011. Biocompatibility of patient-contacting materials was demonstrated by using materials that meet applicable standards or are used in 510(k) cleared devices.
Technological Characteristics:
Subject CROSSWAY™ instruments have similar technological characteristics with minor modifications compared to predicate CROSSWAY™ instruments including design, intended use, material composition, function, and range of sizes.
Basis of Substantial Equivalence:
The CROSSWAY™ System has been found to be substantially equivalent to the predicate devices with respect to technical characteristics, performance, and intended use. The information provided supports substantial equivalence to the predicate devices.
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
510(k) Number (if known)
K190598
Device Name
CROSSWAY™ Spinal Access System
Indications for Use (Describe)
The CROSSWAY™ Spinal Access System is indicated for minimally invasive visualization and access to the anterior spine for assisting in various surgical procedures such as herniated disc repair, biopsy, or harvesting autogenous bone.
Type of Use (Select one or both, as applicable)
[X] Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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§ 888.1100 Arthroscope.
(a)
Identification. An arthroscope is an electrically powered endoscope intended to make visible the interior of a joint. The arthroscope and accessories also is intended to perform surgery within a joint.(b)
Classification. (1) Class II (performance standards).(2) Class I for the following manual arthroscopic instruments: cannulas, currettes, drill guides, forceps, gouges, graspers, knives, obturators, osteotomes, probes, punches, rasps, retractors, rongeurs, suture passers, suture knotpushers, suture punches, switching rods, and trocars. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter, subject to the limitations in § 888.9.