(163 days)
The Spinous Process Plate is intended for fixation to adjacent spinous processes (L1-L5) as an adjunct to anterior interbody fusion and bone graft. The indications for the spinous process plate include spinal trauma, degenerative spondylolisthesis and degenerative disc disease. The spinous process plate should only be used in the presence of a vertebral body replacement device such as the Spinal Concepts, Inc. InFix® System.
The Tandem system consists of spinous process plates and interconnecting male and female grommets. The implants are used in combination with a vertebral body replacement device such as the Spinal Concepts, Inc. InFix System. The plates feature a slim profile, several rows of spikes, and holes on each end with a spherical seat for grommet attachment. The spikes around the plate holes resist plate rotation after implantation, while a row of spikes over the intraspinous ligament aids in fixation to any optional bone graft.
It appears there might be a misunderstanding regarding the nature of the provided document. The text is a 510(k) summary for a medical device (Spinal Concepts, Inc. Tandem Spinous Process Plate System), which is a premarket notification to the FDA.
This document describes a mechanical surgical implant and its regulatory approval process, not an AI or software-based device that would typically have "acceptance criteria" and be "proven to meet the acceptance criteria" through clinical studies in the way you've outlined with terms like "test set," "ground truth," "MRMC," or "standalone performance."
For this type of device, "acceptance criteria" are generally related to its physical and functional properties, and "proof" comes from mechanical testing and demonstrating substantial equivalence to a predicate device.
Given this context, I cannot provide the information in the format requested as it's not applicable to this document. However, I can extract the relevant information pertaining to the device's assessment from the provided text:
Summary of Device Assessment from K040096: Spinal Concepts, Inc. Tandem Spinous Process Plate System
1. Acceptance Criteria and Reported Device Performance (as inferred for a mechanical device):
| Acceptance Criteria (Inferred for a Mechanical Implant) | Reported Device Performance (from K040096) |
|---|---|
| Functional requirements under normal physiologic loads | "Mechanical testing demonstrated that the Tandem System exhibits the functional requirements to support its use as a spinous process plate system under normal physiologic loads in the spine." |
| Substantial Equivalence to Predicate Device | The FDA determined the device is "substantially equivalent...to legally marketed predicate devices." |
| Adherence to relevant regulations | The FDA states the device is subject to general controls and warns of other requirements (registration, listing, GMP, labeling, etc.). |
2. Sample size used for the test set and the data provenance:
- Not applicable in the way specified. For this mechanical device, the "test set" would refer to physical prototypes or samples subjected to mechanical stress tests. The document does not specify the number of samples used in these tests.
- Data Provenance: The mechanical test data would be generated in a lab setting, likely by the manufacturer (Spinal Concepts, Inc.). The exact country of origin for the testing is not specified, but the manufacturer is based in Austin, TX, USA. The testing would be prospective in the sense that the device was tested to demonstrate its capabilities before widespread use.
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. The "ground truth" for a mechanical device like this is established through engineering principles, material science, and biomechanical standards, not expert consensus on images or clinical outcomes in the same way an AI device would be evaluated. The mechanical performance itself (e.g., load-bearing capacity, fatigue resistance) is the "ground truth" being measured.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable. This concept pertains to resolving discrepancies in expert interpretations, which is not relevant to mechanical testing results. Mechanical test results are typically quantitative and objective measurements.
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 surgical implant, not an AI or imaging diagnostic device that would involve human readers or AI assistance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This concept is for AI algorithms, not mechanical implants. The device itself (the implant) is the "standalone" product that undergoes testing.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For mechanical devices, the "ground truth" or standard of comparison is typically based on established engineering standards, biomechanical principles, and the performance of predicate devices. The document states:
- "Mechanical testing demonstrated that the Tandem System exhibits the functional requirements to support its use as a spinous process plate system under normal physiologic loads in the spine." This suggests mechanical properties (strength, stability) as the core "ground truth."
- The FDA determined "substantial equivalence" to a "legally marketed predicate device" (Meurig-Williams Plate). The performance characteristics of the predicate device serve as a benchmark for "ground truth."
8. The sample size for the training set:
- Not applicable. There is no "training set" in the context of a mechanical device undergoing mechanical testing or a 510(k) review for substantial equivalence. "Training set" refers to data used to train an AI algorithm.
9. How the ground truth for the training set was established:
- Not applicable. As there is no "training set" as defined for AI or statistical models, there is no ground truth established for it.
In summary, this document is for a traditional medical device, a surgical implant, and its regulatory clearance is based on mechanical performance and substantial equivalence, not the kind of AI/algorithm performance analysis detailed in your questions.
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K040096 Page 1 of 1
Spinal Concepts, Inc. Tandem Spinous Process Plate System
510(k) Summary of Safety and Effectiveness
JUL 0 1 2004
| SUBMITTED BY | Spinal Concepts, Inc.5301 Riata Park Court, Bldg. FAustin, TX 78727 |
|---|---|
| ESTABLISHMENTREGISTRATION NUMBER | 1649384 |
| CONTACT PERSON | Lisa PetersonRegulatory Affairs Specialist |
| DATE PREPARED | January 14, 2004 |
| CLASSIFICATION NAME | Spinal interlaminal fixation orthosis, 21 CFR 888.3050. Class II. |
| COMMON NAME | Posterior Spinal Fixation System |
| PROPRIETARY NAME | Spinal Concepts, Inc. Tandem Spinous Process Plate System |
| PREDICATE DEVICES | Meurig-Williams Plate |
DEVICE DESCRIPTION
The Tandem system consists of spinous process plates and interconnecting male and female grommets. The implants are used in combination with a vertebral body replacement device such as the Spinal Concepts, Inc. InFix System. The plates feature a slim profile, several rows of spikes, and holes on each end with a spherical seat for grommet attachment. The spikes around the plate holes resist plate rotation after implantation, while a row of spikes over the intraspinous ligament aids in fixation to any optional bone graft.
INDICATIONS
The Tandem Spinous Process Plate is intended for fixation to adjacent spinous processes (L1-L5) as an adjunct to anterior interbody fusion and bone graft. The indications for the spinous process plate include spinal trauma, degenerative spondylolisthesis and degenerative disc disease. The spinous process plate should only be used in the presence of a vertebral body replacement device such as the Spinal Concepts, Inc. InFix® System.
MECHANICAL TEST DATA
Mechanical testing demonstrated that the Tandem System exhibits the functional requirements to support its use as a spinous process plate system under normal physiologic loads in the spine.
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Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
JUL 01 2004
Ms. Lisa Peterson Regulatory Affairs Specialist Spinal Concepts Incorporated 5301 Riata Park Court, Bldg. F Austin, Texas 78727
Re: K040096
Trade Name: Tandem Spinous Process Plate System Regulation Number: 21 CFR 888.3050 Regulation Name: Spinal interlaminal fixation orthosis Regulatory Class: II Product Code: KWP Dated: April 15, 2004 Received: April 20, 2004
Dear Ms. Peterson:
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. 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.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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.
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Page 2 - Ms. Lisa Peterson
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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050. This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (301) 594-4659. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrl/dsma/dsmamain.html.
Sincerely yours,
Miriam C. Provost.
Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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INDICATIONS FOR USE STATEMENT
Page 1 of 1
K040096 510(k) Number (if known):
Spinal Concepts, Inc. Tandem Spinous Process Plate System Device Name:
Indications for Use:
The Spinous Process Plate is intended for fixation to adjacent spinous processes (L1-I no adjunct to anterior interbody fusion and bone graft. The indications for the E7 as an adjance to ancerior issinal trauma, spondylolisthesis and degenerative disc disease. The spinous process plate should only be used in the presence of a vertebral body replacement device such as the Spinal Concepts, Inc. InFix® System.
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
| Prescription Use: (Per 21 CFR 801.109) | X |
|---|---|
| OR | |
| Over-The-Counter: (Optional Format 1-2-96) |
Miriam C. Provost
(Division Sign-Off)
Division of General, Restorative,
and Neurological Devices
510(k) Number K040096
§ 888.3050 Spinal interlaminal fixation orthosis.
(a)
Identification. A spinal interlaminal fixation orthosis is a device intended to be implanted made of an alloy, such as stainless steel, that consists of various hooks and a posteriorly placed compression or distraction rod. The device is implanted, usually across three adjacent vertebrae, to straighten and immobilize the spine to allow bone grafts to unite and fuse the vertebrae together. The device is used primarily in the treatment of scoliosis (a lateral curvature of the spine), but it also may be used in the treatment of fracture or dislocation of the spine, grades 3 and 4 of spondylolisthesis (a dislocation of the spinal column), and lower back syndrome.(b)
Classification. Class II.