(218 days)
The Firebird Spinal Fixation System is intended for posterior, non-cervical pedicle, and non-pedicle fixation (T1-S2/Ilium). The system is limited to use in skeletally mature patients and is intended to be used as an adjunct to fusion using autograft or allograft. The device is indicated for all of the following indications:
-
- 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),
- spinal stenosis, 4)
-
- deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis),
-
- tumor,
-
- pseudoarthrosis, and
-
- failed previous fusion
When used for fixation to the ilium, the offset connectors of the Firebird Spinal Fixation System must be used in conjunction with pedicle screws placed at the S1 or S2 spinal level.
The Firebird Spinal Fixation System components are used with certain components of the SFS system, including rod connectors and cross-connectors.
The additional, non-pedicle components presented in this premarket notification consist of Hooks and Iliac Connectors.
This document is a 510(k) Premarket Notification for the Blackstone Medical, Inc. Firebird Spinal Fixation System Expansion. It indicates that the submission is for an expansion of a previously cleared system, focusing on adding new non-pedicle components (Hooks and Iliac Connectors). Therefore, the "device" in question refers to these additional components for the existing Firebird Spinal Fixation System.
It's important to note that this is a 510(k) submission, which typically demonstrates substantial equivalence to a predicate device rather than independent proof of safety and effectiveness through a clinical trial with specific performance criteria for AI/software-as-a-medical-device. The "performance data" here refers to mechanical testing for the new components.
Here's an analysis based on the provided text, recognizing the context of a spinal implant device and not an AI/software device:
Acceptance Criteria and Device Performance
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Mechanical Performance Equivalent to Predicate Device | - Static compression bending, static torsion, and dynamic compression bending were conducted. |
- Results were compared to the predicate Firebird systems when used for the same intended use of iliac fixation. |
| No New Issues of Safety or Effectiveness | - The mechanical evaluations addressed technical differences. - "These differences do not present any new issues of safety or effectiveness." |
| Substantial Equivalence to Predicate Devices | - The expanded system has the "same intended use and similar indications, technological characteristics and principles of operation" as its predicate systems. - The device was granted 510(k) clearance due to substantial equivalence (K093926). |
Explanation of "Acceptance Criteria" for this device:
For spinal fixation systems like this, acceptance criteria in a 510(k) context are typically demonstrated through:
- Mechanical Testing: Showing that the new components meet established standards for strength, durability, and resistance to wear, and perform comparably to legally marketed predicate devices. The document specifically mentions static compression bending, static torsion, and dynamic compression bending.
- Biocompatibility: (Though not explicitly detailed in this summary, it's an inherent requirement for implantable devices.)
- Design Rationale & Risk Analysis: Demonstrating that the design is appropriate for its intended use and that potential risks have been mitigated.
- Demonstration of Substantial Equivalence: The overarching goal of a 510(k) is to prove the device is as safe and effective as a legally marketed predicate device.
2. Sample Size for Test Set and Data Provenance
This document describes mechanical testing of physical implants, not a clinical study involving a "test set" of patients or data in the way an AI/software device would. Therefore, the concepts of "sample size for the test set" and "data provenance" (country of origin, retrospective/prospective) are not applicable in the context of this 510(k) submission. Mechanical tests would use a certain number of device components but this is not specified as a "sample size" in this document.
3. Number of Experts and Qualifications for Ground Truth
Again, this is a mechanical device submission, not an AI/software device. There were no experts used to establish "ground truth" in the clinical sense for a test set. The "ground truth" for mechanical testing is derived from established engineering standards and comparison to predicate device performance data (often from similar mechanical tests or published data).
4. Adjudication Method
Not applicable. There was no clinical test set requiring expert adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
Not applicable. This submission is for a physical spinal implant, not an AI/software device that would assist human readers in diagnosis or analysis.
6. Standalone (Algorithm Only) Performance
Not applicable. This is a physical medical device; there is no algorithm or standalone software performance to evaluate.
7. Type of Ground Truth Used
The "ground truth" for this device's performance demonstration relies on:
- Engineering Standards: Established international and national standards for spinal implant mechanical testing.
- Predicate Device Performance Data: Mechanical test results from the identified predicate devices (e.g., Firebird Spinal Fixation System Cobalt-Chrome Rods, Blackstone Pedicle Screw System, Synthes Universal Spine System, DePuy Acromed systems). The performance of the new components must demonstrate equivalence to these established predicate devices.
8. Sample Size for the Training Set
Not applicable. As a physical device, there is no "training set" in the context of machine learning or AI.
9. How Ground Truth for the Training Set Was Established
Not applicable. No training set was used.
§ 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.