(88 days)
The Quantum Spinal System components are non-cervical spinal fixation devices intended for use as a pedicle screw system (T1 - S2), a posterior hook and sacral/iliac screw fixation system or as an anterolateral fixation system (T8 - L5). Pedicle screw fixation is limited to skeletally mature patients. These devices are indicated for all of the following indications regardless of the intended use: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma, (i.e., fracture or dislocation), deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis, Scheuermann's Disease), tumor, stenosis, pseudoarthrosis, and failed previous fusion.
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This document describes the Quantum Spinal System, a medical device, and its regulatory clearance through the 510(k) pathway. It does not contain information about acceptance criteria or a study that proves the device meets specific performance criteria in the way that an AI/ML device submission would.
The provided text describes a traditional medical device (spinal fixation system) and its substantial equivalence to predicate devices, rather than an AI/ML device with performance metrics like accuracy, sensitivity, or specificity. Therefore, many of the requested fields are not applicable to the information contained in the provided document.
Here's a breakdown of the available information:
1. Table of Acceptance Criteria and Reported Device Performance:
This information is not provided in a quantifiable way typical for AI/ML device performance. The document states:
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Conformance to ASTM Standards (Mechanical/Material) | "Testing per recognized ASTM standards was presented." |
| Substantial Equivalence to Predicate Devices | "Comparisons of device performance data, materials, indications and design/function to predicate devices were provided in making a determination of substantial equivalence." |
2. Sample size used for the test set and the data provenance:
- Not applicable / Not provided. This document describes a spinal implant, not a data-driven device that requires a "test set" in the AI/ML sense. The performance data refers to mechanical and material testing, not clinical data sets.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable / Not provided. Ground truth, in the context of AI/ML, refers to labels or diagnoses provided by experts on a dataset. This information is not relevant to the clearance of a spinal implant.
4. Adjudication method for the test set:
- Not applicable / Not provided. Adjudication methods are used in AI/ML studies to resolve disagreements among experts in labeling data. This is not pertinent to the current device.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, and the effect size of how much human readers improve with AI vs without AI assistance:
- Not applicable / Not provided. This device is a surgical implant, not an AI-powered diagnostic or assistive tool. Therefore, an MRMC study comparing human readers with and without AI assistance is irrelevant.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Not applicable / Not provided. There is no algorithm for this device.
7. The type of ground truth used:
- Not applicable / Not provided. The "ground truth" for a spinal implant's safety and effectiveness is established through engineering testing (e.g., biomechanical strength, material compatibility), pre-clinical studies, and clinical experience with similar predicate devices, rather than a "ground truth" for data labeling. The regulatory decision is based on substantial equivalence to predicate devices which have an established safety and effectiveness profile.
8. The sample size for the training set:
- Not applicable / Not provided. This device does not involve machine learning; therefore, there is no "training set."
9. How the ground truth for the training set was established:
- Not applicable / Not provided. As there is no training set for an AI/ML model, this question is not relevant.
In summary: The provided document is a 510(k) summary for a traditional medical device (spinal fixation system). The regulatory review for such devices focuses on demonstrating substantial equivalence to legally marketed predicate devices, primarily through engineering performance data (e.g., mechanical testing conforming to ASTM standards), material safety, and similarity in design and intended use. The concepts of "acceptance criteria" and "study proving device meets acceptance criteria" for AI/ML devices, involving test sets, ground truth, experts, and reader studies, are not applicable to this type of traditional device 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.