(187 days)
The Cayman Thoracolumbar Plate System is indicated for use via the lateral or anterolateral surgical approach in the treatment of thoracolumbar (T1-L5) spine and for use as an anteriorly placed supplemental fixation device for the lumbosacral level below the bifurcation of the vascular structures. When properly used this system will help provide temporary stabilization until a solid spinal fusion develops. Specific indications include: a) degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies), b) pseudoarthrosis, c) spondylolisthesis, e) fracture, f) neoplastic disease, g) unsuccessful previous fusion surgery, h) lordotic deformities of the spine, i) idiopathic thoracolumbar or lumbar scoliosis, j) deformity (i.e., scoliosis, kyphosis, and/or lordosis) associated with deficient posterior elements such as that resulting from laminectomy, spina bifida, or myelomenigocele, k) neuromuscular deformity (i.e., scoliosis, lordosis, and/or kyphosis) associated with pelvic obliquity.
The Cayman Thoracolumbar Plate System is a spinal fixation system which consists of screws and plates. All of the components are available in a variety of sizes to match more closely the patient's anatomy. Materials: The devices are manufactured from CP Titanium and Ti6A14V per ASTM and ISO standards. Function: The system functions as an adjunct to fusion to provide immobilization of the spine.
This K081380 document describes the Cayman Thoracolumbar Plate System, a spinal fixation system. However, it does not include a study proving device performance against acceptance criteria in the way one might expect for a diagnostic AI device. This is a 510(k) premarket notification for a medical device (implantable hardware), not a software algorithm or AI.
The "study" referenced here is largely a mechanical testing study to demonstrate substantial equivalence to existing devices.
Here's the information based on the provided text, and where certain requested sections are not applicable to this type of submission:
Cayman Thoracolumbar Plate System Acceptance Criteria and Study Details
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (What they aimed to demonstrate) | Reported Device Performance (How it met the criteria) |
|---|---|
| Mechanical integrity in static compression bending (in accordance with ASTM F17) | Tested successfully in static compression bending per ASTM F17 |
| Mechanical integrity in dynamic compression testing (in accordance with ASTM F17) | Tested successfully in dynamic compression testing per ASTM F17 |
| Mechanical integrity in static torsion (in accordance with ASTM F17) | Tested successfully in static torsion per ASTM F17 |
| Substantial equivalence in design, material, and indications for use to legally marketed predicate devices | Found to be similar in design, material, and indications for use, and expected to be equivalent in safety and effectiveness to predicate devices. |
2. Sample size used for the test set and the data provenance
- Sample Size for Test Set: Not specified in terms of number of physical devices tested; however, standardized mechanical tests (like ASTM F17) typically involve multiple samples to ensure statistical validity. The document indicates the type of tests performed rather than the exact number of units.
- Data Provenance: Not applicable in the context of clinical data for a diagnostic device. The "data" here refers to mechanical test results, which would originate from laboratory testing of the manufactured plates and screws.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. Ground truth in this context would be related to the mechanical properties and performance of the materials and design, which are established by engineering standards and measurements, not clinical expert consensus.
4. Adjudication method for the test set
Not applicable. Adjudication methods are typically used for interpreting clinical data or images, not for evaluating mechanical testing results.
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 spinal implant device, not an AI or diagnostic imaging system.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
Not applicable. This is a spinal implant device, not an AI or algorithm.
7. The type of ground truth used
The "ground truth" for this device's performance is established by engineering standards and mechanical testing specifications (specifically ASTM F17). The performance is compared against the known mechanical properties required for such implants and the performance of predicate devices.
8. The sample size for the training set
Not applicable. There is no "training set" in the context of a mechanical medical device submission like this.
9. How the ground truth for the training set was established
Not applicable.
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NOV 1 9 2008
510(k) SUMMARY for the
Cayman Thoracolumbar Plate System
This safety and effectiveness summary for the Cayman Thoracolumbar Plate System is provided as required per Section 513(i(3) of the Food, Drug and Cosmetic Act.
| 1. Submitter : | Contact Person : | |
|---|---|---|
| K2M, Inc. | Richard W. Woods | |
| 751 Miller Drive SE, | K2M, Inc. | |
| Suite F1 | 751 Miller Drive SE, Suite F1 | |
| Leesburg, VA 20175 | Leesburg, VA 20175 | |
| Telephone: 703-777-3155 | ||
| Date Prepared: | May 13, 2008 |
- Tradename: Cayman Thoracolumbar Plate System Common Name: Thoracolumbar Plates Classification Name: Spinal intervertebral body fixation orthosis (21 CFR 888.3060)
3. Predicate or legally marketed devices which are substantially equivalent :
- � Blackstone Medical Unity Anterior Lumbar Plate Fixation System
- Synthes Thoracolumbar Spine Locking Plate .
- . Medtronic Sofamor Danek Pyramid Anterior Plate Fixation System
- Sofamor Danek Z-Plate .
4. Description of the device:
The Cayman Thoracolumbar Plate System is a spinal fixation system which consists of screws and plates. All of the components are available in a variety of sizes to match more closely the patient's anatomy.
Materials: The devices are manufactured from CP Titanium and Ti6A14V per ASTM and ISO standards,
Function: The system functions as an adjunct to fusion to provide immobilization of the spine.
5. Intended Use:
The Cayman Thoracolumbar Plate System is indicated for use via the lateral or anterolateral surgical approach in the treatment of thoracolumbar (I'l-LS) spine and for use as an anteriorly placed supplemental fixation device for the lumbosacral level below the bifureation of the vascular structures. When properly used this system will help provide temporary stabilization until a solid spinal fusion develops. Specific indications include: a) degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies), b) pseudoarthrosis, c) spondylolisthesis, e) fracture, f) neoplastic disease, g) unsuccessful previous fusion surgery, h) lordotic deformities of the spine, i) idiopathic thoracolumbar or lumbar scoliosis, i) deformity (i.e., scoliosis, and/or lordosis) associated with deficient posterior elements such as that resulting from laminectomy, spina bifida, or myelomenigocele, k) neuromuscular deformity (i.e., scoliosis, lordosis, and/or kyphosis) associated with pelvic obliquity.
6. Technological and Performance Characteristics;
The Cayman Thoracolumbar Plates were tested in static compression bending, dynamic compression testing and static torsion in accordance with ASTM F17 and are considered substantially equivalent to other legally marketed devices. They are similar in design, material, and indications for use and are expected to be equivalent in safety and effectiveness.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
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Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
K2M, Inc. % Mr. Richard W. Woods Senior VP, Enginecring 751 Miller Drive, Southcast, Suite F1 Leesburg, Virginia 20175
NOV 1 9 2008
Re: K081380
Trade/Device Name: Cayman Thoracolumbar Plate System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal intervertebral body fixation orthosis. Regulatory Class: II Product Code: KWQ Dated: November 07, 2008 Received: November 13, 2008
Dear Mr. Woods:
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 (sec 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. Richard W. Woods
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 Biomctric's (OSB's) Division of Postmarket Survcillance at (240) 276-3474. For questions regarding 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 responsibilitics under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Mark H Millman
- 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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Indications for Use
510(k) Number (if known):
Device Name: Cayman Thoracolumbar Plate System
Indications for Use:
The Cayman Thoracolumbar Plate System is indicated for use via the lateral or anterolateral surgical approach in the treatment of thoracolumbar (T1-L5) spine and for use as an anteriorly placed supplemental fixation device for the lumbosacral level below the bifurcation of the vascular structures. When properly used this system will help provide temporary stabilization until a solid spinal fusion develops. Specific indications include: a) degencrative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies), b) pscudoarthrosis, c) spondylolisthesis, e) fracture, f) neoplastic disease, g) unsuccessful previous fusion surgery, h) lordotic deformities of the spine, i) idiopathic thoracolumbar or lumbar scoliosis, j) deformity (i.e., scoliosis, kyphosis, and/or lordosis) associated with deficient posterior elements such as that resulting from laminectomy, spina bifida, or myelomenigocele, k) neuromuscular deformity (i.e., scoliosis, lordosis, and/or kyphosis) associated with pelvic obliquity.
Prescription Use X (Part 21 CFR 801 Subpart D)
AND/OR
Over-the-counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS-LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Dalm
Limm
Pestorative. Division of Gene and Neurological Devices
510(k) Number I 081380
§ 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.