The Range Spinal System is comprised of the DENALI, DENALI DEFORMITY, and MESA Spinal Systems and the ARI Anterior Vertebral Body Staples, all of which are cleared for the following indications:

Non-cervical, pedicle screw fixation devices for posterior stabilization as an adjunct to fusion for the following indications: trauma ( i.e. fracture or dislocation ); spinal stenosis; curvatures (i.e. scoliosis; and/or lordosis); tumor; pseudoarthrosis; and failed previous fusion. It is also indicated for the treatment of severe spondylolisthesis ( grades 3 and 4 ) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine ( L3 to sacrum) with removal of the implants after the attainment of a solid fusion.

Non-cervical, non-pedicle spinal fixation devices intended for posterior or anterolateral thoracolumbar screw stabilization as an adjunct to fusion for the following indications: degenerative disease (DDD) (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies ); spondylolisthesis; trauma ( i.e. fracture or dislocation ); spinal stenosis; curvatures ( i.e. scoliosis; and/or lordosis); tumor; pseudoarthrosis; and failed previous fusion.

Device Description

The Mesa Spinal System is a top-loading, multiple component, spinal fixation system. 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 titanium and cobalt chrome per ASTM and ISO standards.

Function: The system functions as an adjunct to provide immobilization and stabilization of spinal segments of the thoracic, lumbar and / or sacral spine.

AI/ML Overview

The provided text pertains to a 510(k) summary for the "Mesa Spinal System" and its substantial equivalence to predicate devices. It describes the device, its intended use, and a comparison to other legally marketed systems, primarily focusing on mechanical testing against ASTM F1717 standards.

However, the document does not contain information about acceptance criteria, a specific study used to prove the device meets those criteria, or details regarding ground truth, expert consensus, or clinical performance data that would typically be found in a study demonstrating effectiveness for a diagnostic or AI-driven device.

This document is for a spinal fixation system, which is a mechanical implant, not a diagnostic or AI device. Therefore, the questions posed (related to AI performance, expert ground truth, multi-reader studies, etc.) are not applicable to this type of medical device submission.

The "study" referenced in the document is mechanical testing to ASTM F1717.

Here's how to address the prompt based on the provided text, while acknowledging the limitations:

1. A table of acceptance criteria and the reported device performance

Acceptance Criteria (Implied from text)	Reported Device Performance (from text)
Performance equal to or better than predicate and currently marketed systems in ASTM F1717 testing.	"The Mesa Spinal System was mechanically tested and compared to the predicate systems and other currently marketed systems and performed equal to or better than these systems in ASTM testing to F1717."
Substantial equivalence in design features, sizing, materials, and intended use as predicate devices.	"The design features and sizing of the components were also compared and the Range Spinal System was found to be substantially the same as these systems. It is manufactured from the same materials and is indicated for the same intended uses as these systems."
No significant differences that would adversely affect use compared to currently marketed systems.	"There are no significant differences between the Range Spinal Systems currently being marketed which would adversely affect the use of the product."

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

Test Set Sample Size: Not specified in terms of patient data. The "test set" here refers to the components of the Mesa Spinal System subjected to mechanical testing. The number of components tested for ASTM F1717 is not detailed.
Data Provenance: Not applicable in the context of patient data for a mechanical fixation device. The testing is performance-based for the device itself.

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 document describes a mechanical device, not a diagnostic or AI system requiring expert-established ground truth from medical images or clinical outcomes. The "ground truth" for the mechanical testing is defined by the ASTM F1717 standard itself.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

Not applicable. Adjudication methods are typically used for clinical studies involving human interpretation or uncertain outcomes. This document details mechanical testing against a standard.

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

No. This is a mechanical spinal fixation system, not a diagnostic or AI device. An MRMC study is not relevant to this type of device.

6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

Not applicable. This is a mechanical device, not an algorithm.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

The "ground truth" in this context is the ASTM F1717 standard for mechanical testing of spinal implant constructs. The device's performance is compared against the requirements and performance characteristics of legally marketed predicate devices as measured under this standard.

8. The sample size for the training set

Not applicable. This is a mechanical device, not an AI system that requires a "training set."

9. How the ground truth for the training set was established

Not applicable. As a mechanical device, a training set and its associated ground truth are not relevant concepts for this submission.

Summary

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510(k) Summary for the Mesa Spinal System, Keystone Rods

This safety and effectiveness summary for the Range Spinal System is provided as required per Section 513(i)(3) of the Food, Doug and Cosmetic Act.

Submitter : K2M, Inc. 751 Miller Drive SE, Suite F 1 Leesburg, VA 20175

Date Prepared: April 07, 2011

Tradename: Mesa Spinal System Spinal Fixation System Common Name: Orthosis, Spinal Pedicle Fixation (21 CFR 888.3070) Classification Name:

3. Predicate or legally marketed devices which are substantially equivalent :

Mesa Spinal System ( K2M, Inc.) .
. Range Spinal System ( K2M, Inc.)
Easyspine (LDR Spine) .

4. Description of the device :

The Mesa Spinal System is a top-loading, multiple component, spinal fixation system. 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 titanium and cobalt chrome per ASTM and ISO standards.

Function: The system functions as an adjunct to provide immobilization and stabilization of spinal segments of the thoracic, lumbar and / or sacral spine.

5. Intended Use:

The Range Spinal System is comprised of the DENALI, DENALI DEFORMITY, and MESA Spinal Systems and the ARI Anterior Vertebral Body Staples, all of which are cleared for the following indications:

6. Comparison of the technological characteristics of the device to predicate and legally marketed devices :

The Mesa Spinal System was mechanically tested and compared to the predicate systems and other currently marketed systems and performed equal to or better than these systems in ASTM testing to F1717. The design features and sizing of the components were also compared and the Range Spinal System was found to be substantially the same as these systems. It is manufactured from the same materials and is indicated for the same intended uses as these systems.

There are no significant differences between the Range Spinal Systems currently being marketed which would adversely affect the use of the product. It is substantially equivalent to these other devices in function, material, sizes, and intended use.

Contact Person : Nancy Giezen Manager Regulatory Affairs 751 Miller Drive SE, Suite F1 Leesburg, VA 20175 Telephone: 703-777-3155

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Image /page/1/Picture/1 description: The image shows a logo for the Department of Health & Human Services. The logo consists of a stylized symbol resembling three overlapping human figures or abstract shapes, positioned to the right of the text. The text, "DEPARTMENT OF HEALTH & H. S.", is arranged in a semi-circular fashion around the left side of the symbol.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

K2M, Inc. % Ms. Nancy Giezen Manager, Regulatory Affairs 751 Miller Drive SE, Suite F1 Leesburg, Virginia 20175

AUG - 2 2011

Re: K110991

Trade/Device Name: Mesa Spinal System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class II Product Code: MNI Dated: July 08, 2011 Received: July 11, 2011

Dear Ms. Giezen:

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. Iisting of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you; however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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

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Page 2 -- Ms. Nancy Giezen

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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act): 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours.

Mark M Millken

Mark N. Melkerson Director Division of Surgical, Orthopedic And Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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510(k) Number (if known):

Mesa Spinal System Device Name :

Indications For Use :

The Range Spinal System is comprised of the DENALI DEFORMITY, and MESA Spinal The Kange Upinal Uystem is compresses Body Staples, all of which are cleared for the following indications:

Non-cervical, pedicle screw fixation devices for posterior stabilization as an adjunct to fusion for the Noll-Civical, podicio scrow thation active or dislocation ); spinal stenosis; curvatures (i.e. scoliosis, kyphosis; and/or lordosis); tumor, pseudoarthrosis; and failed previous fusion. It is also indicated for Kyphosis, and of totaosis), taillor, procused in and 4 ) of the LS-S1 vertebra in skeletally mature the treatment of severe sponsylonouses ( graft having implants attached to the lumbar and sacral pations roof ring rassoir of the implants after the attainment of a solid fusion.

Non-cervical, non-pedicle spinal fixation devices intended for posterior or anterolateral Non-Colvical, non pource opinia ins an adjunct to fusion for the following indications: degenerative thoraconamour of on in befined as back pain of discogenic origin with degeneration of the disc urse discuse (1 ) ( Don't madiographic studies ); spondylolisthesis; trauma ( i.e. fracture or dislocation ); spinal stenosis; curvatures ( i.e. scoliosis; and/or lordosis); tumor; pseudoarthrosis; and failed previous fusion.

Prescription use X

Over-the-counter use ( PER 21 CFR 801.109)

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED NEEDED

Concurrence of CDRH, Office of Device Evaluation ( ODE )

(Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices

510(k) Number_ K110991

Regulation Number and Section

§ 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.