(142 days)
The SSP Pedicle Screw System is indicated for the treatment of severe spondylolisthesis (Grade 3 and 4) of the L5-S1 vertebra in skeletally mature patients undergoing fusion by autogenous bone grafting having implants attached to the lumbar and sacral spine with removal of implants after the attainment of a solid fusion.
The SSP Pedicle Screw System also is 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 thoracic, lumbar, and sacral spine: degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, spinal stenosis, dislocation, scoliosis, kyphosis, lordosis, spinal turnor, pseudoarthrosis, and failed previous fusion.
The SSP Pedicle Screw System is an internal fixation device for spinal surgery consisting of rods, pedicle screws and transverse links. To enable close conformance to patient anatomy, pedicle screws and rods are available in various lengths, diameters, and/or contours. A series of manual surgical instruments (not a subject of this submission) intended to assist the insertion and placement of the implants are provided in an instrument tray.
This submission is a 510(k) premarket notification for a Class II medical device, the SSP Pedicle Screw System. The primary purpose of a 510(k) is to demonstrate substantial equivalence to a legally marketed predicate device, not necessarily to prove the device meets specific acceptance criteria through a clinical study. Therefore, the information requested regarding acceptance criteria and a study proving device performance in the context of clinical efficacy, reader studies, and ground truth establishment is not typically found in a standard 510(k) summary for this type of device.
510(k) submissions for pedicle screw systems usually focus on:
- Substantial Equivalence: Comparing the new device's indications for use, technological characteristics, and performance data (often mechanical testing) to a predicate device.
- Mechanical Testing: Demonstrating that the device meets established ASTM or ISO standards for strength, fatigue, and other biomechanical properties.
Based on the provided text, here's what can be extracted and what cannot:
1. A table of acceptance criteria and the reported device performance
- Acceptance Criteria: Not explicitly stated in terms of clinical performance or diagnostic accuracy, as this is a surgical implant. The acceptance criteria for a 510(k) of this nature would primarily be the demonstration of substantial equivalence to a predicate device and satisfactory mechanical testing results (which are not detailed in this summary).
- Reported Device Performance: The document states, "Specialty Spine Products, LLC has submitted information to demonstrate that... the SSP Pedicle Screw System is substantially equivalent in indications and design principles to predicate devices..." This "performance" is in the context of equivalence, not a clinical outcome measure described by a specific metric (sensitivity, specificity, etc.).
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 for clinical studies in this 510(k). This is not a diagnostic device or an AI-based system that would typically have a "test set" in the sense of patient data for performance evaluation. If a "test set" were to be considered, it would refer to the samples used in mechanical testing (e.g., number of screws tested for fatigue), but this specific information is not provided in the summary.
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 device is a surgical implant, not a diagnostic tool requiring expert interpretation of results to establish ground truth for a test set.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. This relates to clinical or diagnostic study outcomes, which are not detailed here.
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 device does not 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 is not an algorithmic device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not applicable. The "ground truth" for a medical implant like this is usually established through adherence to engineering design specifications, material properties, and mechanical performance standards, compared against predicate devices and relevant ASTM/ISO standards. Clinical efficacy would be demonstrated in post-market surveillance or larger clinical trials, which are beyond the scope of a 510(k) that establishes substantial equivalence.
8. The sample size for the training set
- Not applicable. There is no "training set" in the context of an AI device for this submission.
9. How the ground truth for the training set was established
- Not applicable. There is no "training set" for an AI device.
Summary of available information relevant to acceptance criteria and study:
The 510(k) summary provided mostly pertains to regulatory and administrative information, device description, intended use, and the declaration of substantial equivalence. The "study" mentioned is the submission of information to demonstrate substantial equivalence to predicate devices, which is the core requirement for a 510(k) clearance. This equivalence relies on comparing indications for use, technological characteristics (materials, design, manufacturing methods), and typically includes mechanical testing data (though not detailed here) to ensure the new device performs at least as safely and effectively as the predicate.
For devices like this, the "acceptance criteria" are predominantly those defined by FDA guidance documents for pedicle screw systems and relevant mechanical testing standards (e.g., ASTM F1717-96 for spinal implant constructs, ASTM F1798 for fatigue testing of pedicle screw systems), against which the device's mechanical performance would be evaluated to ensure it meets acceptable safety and integrity thresholds. The document explicitly states the FDA reviewed the information and "determined the device is substantially equivalent." This determination is the "proof" that the device meets the regulatory acceptance criteria for 510(k) clearance.
§ 888.3070 Thoracolumbosacral pedicle screw system.
(a)
Identification. (1) Rigid pedicle screw systems are comprised of multiple components, made from a variety of materials that allow the surgeon to build an implant system to fit the patient's anatomical and physiological requirements. Such a spinal implant assembly consists of a combination of screws, longitudinal members (e.g., plates, rods including dual diameter rods, plate/rod combinations), transverse or cross connectors, and interconnection mechanisms (e.g., rod-to-rod connectors, offset connectors).(2) Semi-rigid systems are defined as systems that contain one or more of the following features (including but not limited to): Non-uniform longitudinal elements, or features that allow more motion or flexibility compared to rigid systems.
(b)
Classification. (1) Class II (special controls), when 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: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra; degenerative spondylolisthesis with objective evidence of neurologic impairment; fracture; dislocation; scoliosis; kyphosis; spinal tumor; and failed previous fusion (pseudarthrosis). These pedicle screw spinal systems must comply with the following special controls:(i) Compliance with material standards;
(ii) Compliance with mechanical testing standards;
(iii) Compliance with biocompatibility standards; and
(iv) Labeling that contains these two statements in addition to other appropriate labeling information:
“Warning: The safety and effectiveness of pedicle screw spinal systems have been established only for spinal conditions with significant mechanical instability or deformity requiring fusion with instrumentation. These conditions are significant mechanical instability or deformity of the thoracic, lumbar, and sacral spine secondary to severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra, degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudarthrosis). The safety and effectiveness of these devices for any other conditions are unknown.”
“Precaution: The implantation of pedicle screw spinal systems should be performed only by experienced spinal surgeons with specific training in the use of this pedicle screw spinal system because this is a technically demanding procedure presenting a risk of serious injury to the patient.”
(2) Class II (special controls), when a rigid pedicle screw system is intended to provide immobilization and stabilization of spinal segments in the thoracic, lumbar, and sacral spine as an adjunct to fusion in the treatment of degenerative disc disease and spondylolisthesis other than either severe spondylolisthesis (grades 3 and 4) at L5-S1 or degenerative spondylolisthesis with objective evidence of neurologic impairment. These pedicle screw systems must comply with the following special controls:
(i) The design characteristics of the device, including engineering schematics, must ensure that the geometry and material composition are consistent with the intended use.
(ii) Non-clinical performance testing must demonstrate the mechanical function and durability of the implant.
(iii) Device components must be demonstrated to be biocompatible.
(iv) Validation testing must demonstrate the cleanliness and sterility of, or the ability to clean and sterilize, the device components and device-specific instruments.
(v) Labeling must include the following:
(A) A clear description of the technological features of the device including identification of device materials and the principles of device operation;
(B) Intended use and indications for use, including levels of fixation;
(C) Identification of magnetic resonance (MR) compatibility status;
(D) Cleaning and sterilization instructions for devices and instruments that are provided non-sterile to the end user; and
(E) Detailed instructions of each surgical step, including device removal.
(3) Class II (special controls), when a semi-rigid system is intended to provide immobilization and stabilization of spinal segments in the thoracic, lumbar, and sacral spine as an adjunct to fusion for any indication. In addition to complying with the special controls in paragraphs (b)(2)(i) through (v) of this section, these pedicle screw systems must comply with the following special controls:
(i) Demonstration that clinical performance characteristics of the device support the intended use of the product, including assessment of fusion compared to a clinically acceptable fusion rate.
(ii) Semi-rigid systems marketed prior to the effective date of this reclassification must submit an amendment to their previously cleared premarket notification (510(k)) demonstrating compliance with the special controls in paragraphs (b)(2)(i) through (v) and paragraph (b)(3)(i) of this section.