(145 days)
The Trivergent Spinal Fixation System is intended to provide immobilization of a single spinal segment in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of lumbar and sacral spine from L2-S1: degenerative disc disease (DDD) (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spinal stenosis; and failed previous fusion.
The Trivergent Spinal Fixation System is a pedicle screw system intended to stabilize and immobilize the L2-S1 spinal segments as an adjunct to fusion. The system includes a variety of screws and plates along with guides, guidewires, drills, drivers, handles, and tans.
The Trivergent Spinal Fixation System plates and screws are available in a variety of geometries to accommodate various patient anatomies. The Trivergent screws come in lengths from 45mm to 60mm, and the Trivergent plates come in angles from 60° to 75°.
The Trivergent Spinal Fixation System implants and instruments are provided non-sterile and are to be sterilized by the end user.
The Trivergent Spinal Fixation System implants are machined from Ti-6A1-4V ELI per ASTM F136.
This document describes the Trivergent Spinal Fixation System, a medical device. Based on the provided text, it's a 510(k) Premarket Notification for a Class II medical device, specifically a pedicle screw system. These submissions primarily focus on demonstrating substantial equivalence to a legally marketed predicate device, rather than providing detailed clinical study results for novel AI-powered diagnostics.
Therefore, the information typically found in an AI/ML medical device submission (such as acceptance criteria for AI performance, clinical study design for AI efficacy, expert adjudication, etc.) is not present in this document. The "Performance Testing Summary" section focuses on bench testing of the physical device (e.g., static compression, fatigue testing) and a cadaver usability study, which are standard for orthopedic implants, not AI/ML algorithms.
Based on the provided text, I cannot answer the questions directly as they pertain to an AI/ML device's acceptance criteria and proving its performance.
Here's why and what information is available:
- Device Type: This is a physical orthopedic implant (spinal fixation system), not an AI/ML diagnostic or therapeutic device.
- Regulatory Pathway: 510(k) demonstrates substantial equivalence, primarily through non-clinical (bench) testing and comparison to predicates, not typically extensive human clinical trials to establish efficacy akin to AI-driven diagnostics.
- Lack of AI/ML Specifics: There is no mention of algorithms, machine learning, image analysis, or any other AI-related components.
Therefore, the questions regarding acceptance criteria for AI performance, sample sizes for AI test/training sets, expert ground truth, MRMC studies, or standalone algorithm performance simply do not apply to the content of this particular document.
If this document were for an AI/ML device, the required information would be detailed under sections like "Clinical Performance Data," "Software Validation," or "Algorithm Performance Benchmarks." This document is focused on the mechanical and material properties of a physical implant.
§ 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.