(45 days)
The Accin™ Cervical Plate System is intended for anterior interbody fixation of the cervical spine. The system is indicated for use in the temporary stabilization of the anterior spine during the development of cervical spine fusions in patients with degenerative disk disease (as defined by neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); trauma (including fracture); tumor; deformity (defined as kyphosis, lordosis or scoliosis); pseudoarthrosis; and/or failed previous fusions. The Accin™ Cervical Plate System can be implanted in the sub-axial cervical spine from C3 through C7.
The Accin™ Cervical Plate System consists of titanium cervical plates and both self-tapping and self-drilling screw components. The surgeon uses the components to make a construct that is placed anteriorly for spinal fixation. The construct is used for temporary fixation which allows for fusion of the cervical spine
The provided FDA 510(k) submission for the Accin™ Cervical Plate System does not describe a study involving an AI/Machine Learning device or software. Instead, it concerns a traditional medical device classification. Therefore, the questions related to AI device performance, sample sizes for test and training sets, ground truth establishment, expert adjudication, or MRMC studies are not applicable to this submission.
The acceptance criteria and the study performed relate to the mechanical and material equivalence of the Accin™ Cervical Plate System to its predicate devices.
1. A table of acceptance criteria and the reported device performance:
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Material Equivalence to Predicate Device | "The Accin™ Cervical Plate System consists of plates and screws manufactured from the same titanium alloy as the Vertebron, Inc. SPC and SSP Cervical Plate Systems." |
| Functional Performance Equivalence to Predicate Device | "The proposed device was equivalent to the predicate device for all testing performed." (This implies that the device met the performance standards demonstrated by the predicate.) |
| Compliance with FDA Guidance Document "Spinal System 510(k)s" | "Testing has shown that the proposed device meets the requirements of the current FDA Guidance document entitled 'Spinal System 510(k)s' dated May 3, 2004." (This signifies that the device's design, materials, and testing protocols align with FDA recommendations for spinal implant systems, demonstrating safety and effectiveness.) |
| Static and Fatigue Performance (as per ASTM F1717) | "Tests were performed on the cervical plate system. The testing was performed in accordance with ASTM F1717, Standard Test Methods for Static and Fatigue for Spinal Implant Constructs in a Vertebrectomy Model." (The reported performance is that it was "equivalent to the predicate device" under these tests, indicating it met the same static and fatigue strength requirements.) |
Summary of the Study:
The study conducted was a bench testing comparison study, not a clinical trial or an AI/ML performance study. The primary goal was to demonstrate substantial equivalence to legally marketed predicate devices (Vertebron SCP and SSP Cervical Plate Systems) based on material composition and mechanical performance.
2. Sample size used for the test set and the data provenance:
- Sample Size: The document does not specify the exact number of devices or components tested. It only states, "Tests were performed on the cervical plate system." For bench testing, sample sizes are typically determined by statistical methods for materials science or engineering, but this detail is not provided.
- Data Provenance: The data comes from laboratory bench testing performed by or for Accelerated Innovation, LLC. There is no information on the country of origin of the data beyond the submitter being in Clifton, NJ, USA. The study is a prospective test in the sense that the testing was performed on the new device (Accin™) specifically to support its 510(k) submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. This was bench testing against a standard (ASTM F1717) and comparison to a predicate device's established performance, not a study requiring expert clinical ground truth assessment.
4. Adjudication method for the test set:
- Not applicable. This was mechanical testing, not a subjective assessment requiring adjudication. The results would be quantitative measurements of physical properties.
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 study does not involve human readers or AI.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This study does not involve an algorithm or AI.
7. The type of ground truth used:
- The "ground truth" in this context is the established mechanical performance characteristics and material composition of the predicate devices, as well as the requirements outlined in the ASTM F1717 standard and the FDA guidance document "Spinal System 510(k)s." The device's performance was compared directly to these objective benchmarks.
8. The sample size for the training set:
- Not applicable. This is not an AI/ML study, so there is no training set.
9. How the ground truth for the training set was established:
- Not applicable. There is no training set.
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Accin™ Cervical Plate System Premarket Notification Submission - 510(k)
Summary of Safety and Effectiveness
| Submitter: | Michael KvitnitskyAccelerated Innovation, LLC1033 US Highway 46, Suite A204Clifton, NJ 07103 | |
|---|---|---|
| Date Prepared: | December 10, 2007 | JAN 31 2008 |
| Device: | Accin™ Cervical Plate System | |
| Classification: | 87KWQ - Appliance, Fixation, Spinal Intervertebral Body, 21CFR 880.3060,Class II | |
| Predicate Device: | Vertebron SCP and SSP Cervical Plate Systems - K040003, K043181, K051815and K062110 | |
| Device Description: | The Accin™ Cervical Plate System consists of titanium cervical plates and bothself-tapping and self-drilling screw components. The surgeon uses thecomponents to make a construct that is placed anteriorly for spinal fixation. Theconstruct is used for temporary fixation which allows for fusion of the cervicalspine | |
| Intended Use: | The Accin™ Cervical Plate System is intended for anterior interbody fixation ofthe cervical spine. The system is indicated for use in the temporary stabilizationof the anterior spine during the development of cervical spine fusions in patientswith degenerative disk disease (as defined by neck pain of discogenic origin withdegeneration of the disc confirmed by history and radiographic studies); trauma(including fracture); tumor; deformity (defined as kyphosis, lordosis or scoliosis);pseudoarthrosis; and/or failed previous fusions. The Accin™ Cervical PlateSystem can be implanted in the sub-axial cervical spine from C3 through C7. |
Comparison to Predicates:
The Accin™ Cervical Plate System consists of plates and screws manufactured from the same titanium alloy as the Vertebron, Inc. SPC and SSP Cervical Plate Systems. Therefore, the devices are equivalent to the Vertebron, Inc. SPC and SSP Cervical Plate Systems.
Accin™ has determined that any differences in the proposed device will not impact the safety or effectiveness of the cervical plate system for its intended use. Testing has shown that the proposed device meets the requirements of the current FDA Guidance document entitled "Spinal System 510(k)s" dated May 3, 2004, and that the proposed device is equivalent to the predicate device.
Synopsis of Test Methods and Results:
Tests were performed on the cervical plate system. The testing was performed in accordance with ASTM F1717, Standard Test Methods for Static and Fatigue for Spinal Implant Constructs in a Vertebrectomy Model. The proposed device was equivalent to the predicate device for all testing performed.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/1/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized symbol that resembles an abstract caduceus or a family of three figures.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
JAN 31 2008
Accelerated Innovations, LLC % Mr. Michael Kvitnitsky Chief Operating Officer 1033 US Highway 46, Suite A204 Clifton, NJ 07103
Re: K073530
Trade/Device Name: Accin™ Cervical Plate System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal intervertebral body fixation orthosis Regulatory Class: II Product Code: KWQ Dated: December 12, 2007 Received: December 19, 2007
Dear Mr. Kvitnitsky:
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.
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.
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Page 2 - Mr. Michael Kvitnitsky
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 Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at (240) 276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at (240) 276-3464. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at toll-free number (800) 638-2041 or (240) 276-3150 or the Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Mark M. Mullens
Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Accin™ Cervical Plate System Premarket Notification Submission - 510(k)
Indications for Use Form
510(k) Number (if known):
Device Name: Accin™ Cervical Plate System
Indications for Use:
The Accin™ Cervical Plate System components are intended for anterior interbody fixation of the cervical spine. The system is indicated for use in the temporary stabilization of the anterior spine during the development of cervical spine fusions in patients with:
- Degenerative disk disease (as defined by neck pain of discogenic origin with . degeneration of the disc confirmed by history and radiographic studies);
- Trauma (including fractures) .
- Tumor .
- Deformity (defined as kyphosis, lordosis or scollosis) .
- Pseudoarthrosis ●
- Failed previous fusions. .
The Accin Cervical Plate System can be implanted in the sub-axial cervical spine from C3 through C7.
Prescription Use X (Per 21 CFR 801.109)
OR
Over-The-Counter Use (Optional Format 1-2-96)
(PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Coneangince of DRH. Office
Willem Muench
Division Sign
Page 1 of 1
and Neurological Devices
510(k) Number K62530
§ 888.3060 Spinal intervertebral body fixation orthosis.
(a)
Identification. A spinal intervertebral body fixation orthosis is a device intended to be implanted made of titanium. It consists of various vertebral plates that are punched into each of a series of vertebral bodies. An eye-type screw is inserted in a hole in the center of each of the plates. A braided cable is threaded through each eye-type screw. The cable is tightened with a tension device and it is fastened or crimped at each eye-type screw. The device is used to apply force to a series of vertebrae to correct “sway back,” scoliosis (lateral curvature of the spine), or other conditions.(b)
Classification. Class II.