(117 days)
When used as a pedicle screw fixation system in the non-cervical posterior spine (TI-SI) in skeletally mature patients, the VICEROY Spine System is 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: (1) degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies), (2) degenerative spondylolisthesis with objective evidence of neurologic impairment, (3) fracture, (4) dislocation, deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis), (5) spinal stenosis, (6) curvatures (i.e., scoliosis, and/or lordosis, (7) turnor, (8) failed previous fusion (i.e. pseudarthrosis).
The VICEROY Spine System consists of four or more pedicle screws and two VICEROY solid rods in a symmetric, bilateral arrangement. The pedicle screws are placed axially in the pedicles with two screws in the cephalad position and two screws in the caudad position. The VICEROY rods are secured in the heads of the pedicle screws so that fixed stabilization is provided between the cephalad and caudad vertebrae. Cross-links can be used if additional stabilization is necessary. The VICEROY Spine System is fabricated from titanium alloy (Ti-6Al-4V ELI) that conforms to the ASTM F136, Standard Specifications for Wrought Titanium-6Aluminum-4VanadiumELI (Extra Low Interstitial) Alloy or Surgical Implant Applications.
The provided text describes a 510(k) premarket notification for a medical device called the VICEROY Spinal System. This document focuses on demonstrating substantial equivalence to predicate devices rather than proving the device meets specific performance acceptance criteria through clinical studies or extensive standalone algorithm evaluation. The "performance summary" section refers to mechanical testing of the device, not a study of its clinical or diagnostic accuracy.
Therefore, many of the requested fields regarding acceptance criteria related to diagnostic performance or clinical outcomes, and the type of study that proves it, are not applicable or cannot be extracted from this document.
Here's a breakdown of what can be extracted:
Acceptance Criteria and Device Performance (Mechanical Testing)
The document states: "Testing was performed to support the equivalence of the proposed pedicle screw system in accordance with FDA Guidance 'Guidance for Industry and FDA Staff: Spinal System 510(k)s.' The following testing was performed in accordance with ASTM F1717: static compression bending, static torsion, and dynamic compression bending."
This indicates that the acceptance criteria are adherence to ASTM F1717 standards for the specified mechanical tests, and the device performs in a manner equivalent to predicate devices under these tests. However, specific numerical acceptance values or detailed performance results (e.g., specific bending moment values, torsion limits) are not provided in this summary. The document only states that the testing supports equivalence.
| Acceptance Criteria Category | Specific Acceptance Criteria (Not Explicitly Quantified in Document) | Reported Device Performance (Implied by Substantial Equivalence Claim) |
|---|---|---|
| Static Compression Bending | Adherence to ASTM F1717 standards for pedicle screw spinal systems. | Performance equivalent to predicate devices. |
| Static Torsion | Adherence to ASTM F1717 standards for pedicle screw spinal systems. | Performance equivalent to predicate devices. |
| Dynamic Compression Bending | Adherence to ASTM F1717 standards for pedicle screw spinal systems. | Performance equivalent to predicate devices. |
Study Details (Mechanical Testing)
- Sample size used for the test set and the data provenance: Not specified in the document. Mechanical testing typically uses a certain number of device samples, but this information is not provided. The data provenance is implied to be from the manufacturer's internal testing as part of the 510(k) submission process.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. This is mechanical testing of a physical device, not related to expert interpretation or ground truth establishment for diagnostic purposes.
- Adjudication method for the test set: Not applicable.
- 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 device is a pedicle screw spinal system, not an AI-powered diagnostic tool.
- If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: Not applicable. This is a physical implant, not an algorithm.
- The type of ground truth used: For mechanical testing, the "ground truth" would be the engineering specifications and performance characteristics defined by ASTM F1717, to which the device's measured performance is compared.
- The sample size for the training set: Not applicable. There is no concept of a "training set" for this type of mechanical testing.
- How the ground truth for the training set was established: Not applicable.
Summary of what the document does convey:
- The VICEROY Spinal System is a medical device intended for spinal stabilization.
- The manufacturer is seeking substantial equivalence to existing predicate devices (ACME Spinal System, Moss Miami, and Expedium Spinal System).
- Substantial equivalence is claimed based on materials, design, indications for use, operational principles, and mechanical testing.
- Mechanical testing was performed according to ASTM F1717 standards for static compression bending, static torsion, and dynamic compression bending.
- The document implies the device met the requirements of these standards and demonstrated performance equivalent to the predicate devices.
§ 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.