K Number
K213034
Device Name
SpineAR SNAP
Date Cleared
2022-09-29

(373 days)

Product Code
Regulation Number
882.4560
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
SpineAR SNAP is intended for use or pre-operative surgical planning on-screen and in a virtual environment, and intraoperative surgical planning and visualization on-screen and in an augment using the HoloLens2 and Magic Leap 1 AR headset displays with validated navigation systems as identified in the device labeling. SpineAR SNAP is indicated for spinal stereotaxic surgery, and where reference to a rigid anatomical structure, such as the spine, can be identified relative to images of the anatomy. SpineAR is intended for use in spinal implant procedures, such as Pedicle Screw Placement, in the lumbar and thoracic regions with the Magic Leap 1 AR headset, and in the lumbar region with the HoloLens2 AR headset. The virtual display should not be relied upon solely for absolute positional information and should always be used in conjunction with the displayed 2D stereotaxic information.
Device Description
The SpineAR SNAP does not require any custom hardware and is a software-based device that runs on a high-performance desktop PC assembled using "commercial off-the-shelf" components that meet minimum performance requirements. The SpineAR SNAP software transforms 2D medical images into a dynamic interactive 3D scene with multiple point of views for viewing on a high-definition (HD) touch screen monitor. The surgeon prepares a pre-operative plan for stereotaxic spine surgery by inserting guidance objects such as directional markers and virtual screws into the 3D scene. Surgical planning tools and functions are available on-screen and when using a virtual reality (VR) headset. The use of a VR headset for preoperative surgical planning further increases the surgeon's immersion level in the 3D scene by providing a 3D stereoscopic display of the same 3D scene displayed on the touch screen monitor. By interfacing to a 3rd party navigation system such as a Medtronic StealthStation S8, the SpineAR SNAP extracts the navigation data (i.e. tool position and orientation) and presents the navigation data into the advanced interactive, high quality 3D image, with multiple point of views on a high-definition (HD) touch screen monitor. Once connected, the surgeon can then execute the plan through the intraoperative use of the SpineAR SNAP's enhanced visualization and guidance tools. The SpineAR SNAP supports three (3) guidance options from which the surgeon selects the level of guidance that will be shown in the 3D scene. The guidance options are dotted line (indicates deviation distance), orientation line (indicates both distance and angular deviation), and ILS (indicates both distance and angular deviation using crosshairs). Visual color-coded cues indicate alignment of the tracker tip to the guidance object (e.g. green = aligned). The 3D scene with guidance tools can also be streamed into an AR wireless headset (Magic Leap 1 or HoloLens2) worn by the surgeon during surgery. The 3D scene and guidance shown within the AR headset is projected above the patient and does not obstruct the surgeons view of the surgical space.
More Information

No
The description focuses on 3D rendering, visualization, navigation data integration, and guidance tools based on pre-operative planning and real-time tracking. There is no mention of algorithms that learn from data or perform tasks typically associated with AI/ML, such as image analysis for automated feature detection, predictive modeling, or adaptive guidance based on learned patterns. The "Not Found" entries for mentions of AI/ML and descriptions of training/test sets further support this conclusion.

No

Explanation: The device is a surgical planning and visualization tool, providing guidance and enhanced visualization for spinal surgeries, but it does not directly treat or prevent a disease or condition.

No

Explanation: The device is intended for surgical planning and visualization, utilizing 2D medical images to create a 3D scene for surgical guidance during spinal procedures. It does not perform any diagnostic function.

No

While the core functionality is software, the device description and performance studies explicitly mention and validate the use of specific AR headsets (HoloLens2 and Magic Leap 1) and their performance characteristics (FOV, resolution, latency, etc.), indicating a reliance on and integration with specific hardware components beyond a standard PC. The EMC and wireless coexistence testing also cover these hardware components.

Based on the provided information, the SpineAR SNAP is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening.
  • SpineAR SNAP's Function: The SpineAR SNAP is a software-based device used for pre-operative and intraoperative surgical planning and visualization. It processes medical images (CT, MR, XA) and navigation data to assist surgeons during spinal procedures. It does not analyze biological specimens.
  • Intended Use: The intended use clearly states its purpose is for surgical planning and visualization, not for analyzing samples from the body.
  • Device Description: The description focuses on image processing, 3D scene creation, guidance tools, and integration with navigation systems, all related to surgical procedures on the patient's body.

Therefore, the SpineAR SNAP falls under the category of a surgical planning and navigation system, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

SpineAR SNAP is intended for use or pre-operative surgical planning on-screen and in a virtual environment, and intraoperative surgical planning and visualization on-screen and in an augment using the HoloLens2 and Magic Leap 1 AR headset displays with validated navigation systems as identified in the device labeling.

SpineAR SNAP is indicated for spinal stereotaxic surgery, and where reference to a rigid anatomical structure, such as the spine, can be identified relative to images of the anatomy. SpineAR is intended for use in spinal implant procedures, such as Pedicle Screw Placement, in the lumbar and thoracic regions with the Magic Leap 1 AR headset, and in the lumbar region with the HoloLens2 AR headset.

The virtual display should not be relied upon solely for absolute positional information and should always be used in conjunction with the displayed 2D stereotaxic information.

Product codes

OLO, LLZ

Device Description

The SpineAR SNAP does not require any custom hardware and is a software-based device that runs on a high-performance desktop PC assembled using "commercial off-the-shelf" components that meet minimum performance requirements.

The SpineAR SNAP software transforms 2D medical images into a dynamic interactive 3D scene with multiple point of views for viewing on a high-definition (HD) touch screen monitor. The surgeon prepares a pre-operative plan for stereotaxic spine surgery by inserting guidance objects such as directional markers and virtual screws into the 3D scene. Surgical planning tools and functions are available on-screen and when using a virtual reality (VR) headset. The use of a VR headset for preoperative surgical planning further increases the surgeon's immersion level in the 3D scene by providing a 3D stereoscopic display of the same 3D scene displayed on the touch screen monitor.

By interfacing to a 3rd party navigation system such as a Medtronic StealthStation S8, the SpineAR SNAP extracts the navigation data (i.e. tool position and orientation) and presents the navigation data into the advanced interactive, high quality 3D image, with multiple point of views on a high-definition (HD) touch screen monitor. Once connected, the surgeon can then execute the plan through the intraoperative use of the SpineAR SNAP's enhanced visualization and guidance tools.

The SpineAR SNAP supports three (3) guidance options from which the surgeon selects the level of guidance that will be shown in the 3D scene. The guidance options are dotted line (indicates deviation distance), orientation line (indicates both distance and angular deviation), and ILS (indicates both distance and angular deviation using crosshairs). Visual color-coded cues indicate alignment of the tracker tip to the guidance object (e.g. green = aligned).

The 3D scene with guidance tools can also be streamed into an AR wireless headset (Magic Leap 1 or HoloLens2) worn by the surgeon during surgery. The 3D scene and guidance shown within the AR headset is projected above the patient and does not obstruct the surgeons view of the surgical space.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

CT, MR and XA

Anatomical Site

Spinal, Lumbar, Thoracic

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Surgeon, intraoperative

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

  • Software Verification and Validation: Performed to test the software requirements specifications for the SpineAR SNAP.
  • Human Factors and Usability Validation: Demonstrated that the intended users of a SpineAR SNAP can safely and effectively perform tasks for the intended uses in the expected use environments, i.e. intraoperative use of the AR headsets. Validation took place under conditions of simulated use with users providing feedback on the usability of the software for performing defined tasks.
  • Navigation Accuracy testing: Conducted to demonstrate that SpineAR does not negatively affect the navigation accuracy of the connected Medtronic StealthStation 8 surgical navigation system. The final placement of each screw in a spine model was assessed via a post-surgical CT scan and compared to the pre-surgical plan to calculate the absolute displacement of the screw tip and absolute angular error of the screw.
    • Mean Positional/Displacement Error: 1.02 mm
    • Max Positional/Displacement Error: 2.80 mm
    • Mean Trajectory/Angular Error: 1.79°
    • Max Trajectory/Angular Error: 3.00°
  • Verification of virtual screw library: Verified the length and diameter (e.g. 40 mm x 5.5 mm) of virtual screws shown in the 3D model accurately represent the real screws used during surgery, and screws are accurately positioned at the tip of the tracked tool.
  • Performance of the Headset display: Demonstrated by verifying the following elements: Field of View (FOV), resolution, luminance, transmittance, distortion, contrast ratio, temporal, display noise and motion-to-photon latency.
  • Projection latency testing: Performed to assess the time delay between movement of a navigated handheld instrument and its display in the scene shown in the Magic Leap 1 and Microsoft HoloLens2 AR headsets. A time delay requirement of

§ 882.4560 Stereotaxic instrument.

(a)
Identification. A stereotaxic instrument is a device consisting of a rigid frame with a calibrated guide mechanism for precisely positioning probes or other devices within a patient's brain, spinal cord, or other part of the nervous system.(b)
Classification. Class II (performance standards).

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September 29, 2022

Surgical Theater, Inc. Kevin Murrock Sr. Director of Quality and Regulatory 30559 Pinetree Road. Suite 206 Pepper Pike. Ohio 44124

Re: K213034

Trade/Device Name: SpineAR SNAP Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic Instrument Regulatory Class: Class II Product Code: OLO, LLZ Dated: August 26, 2022 Received: August 30, 2022

Dear Kevin Murrock:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies.combination product submissions. 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. 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 or any Federal

1

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 of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Shumava Ali. M.P.H. Assistant Director DHT6C: Division of Restorative, Repair and Trauma Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K213034

Device Name SpineAR SNAP

Indications for Use (Describe)

SpineAR SNAP is intended for use or pre-operative surgical planning on-screen and in a virtual environment, and intraoperative surgical planning and visualization on-screen and in an augment using the HoloLens2 and Magic Leap 1 AR headset displays with validated navigation systems as identified in the device labeling.

SpineAR SNAP is indicated for spinal stereotaxic surgery, and where reference to a rigid anatomical structure, such as the spine, can be identified relative to images of the anatomy. SpineAR is intended for use in spinal implant procedures, such as Pedicle Screw Placement, in the lumbar and thoracic regions with the Magic Leap 1 AR headset, and in the lumbar region with the HoloLens2 AR headset.

The virtual display should not be relied upon solely for absolute positional information and should always be used in conjunction with the displayed 2D stereotaxic information.

Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)

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Image /page/3/Picture/1 description: The image shows the logo for Surgical Theater. The logo consists of a stylized letter "S" in red and orange gradient, followed by the words "SURGICAL" in red and "THEATER" in orange. The word "THEATER" has a registered trademark symbol next to it.

SpineAR SNAP

510(k) SUMMARY

This 510(k) summary of safety and effectiveness information is prepared in accordance with 21 CFR 8807.92.

Date Prepared: 27-Sep-2022

Manufacturer/Submitter:

Surgical Theater, Inc. 30559 Pinetree Road, Suite 206 Pepper Pike, Ohio 44124 Phone: (216) 496-7884 Fax: (216) 916-3806

Establishment Registration Number: 3010197287

Contact Person:

Kevin M. Murrock Sr. Director of Quality and Regulatory Surgical Theater, Inc. 30559 Pinetree Road, Suite 206 Pepper Pike, Ohio 44124 Phone: (330) 472-6520 Email: kmurrock@surgicaltheater.com

Name of Device

  • Trade Name: SpineAR SNAP ● Common Name: Augmented Reality System Classification Name: Orthopedic Stereotaxic Instrument ●
  • Regulation Number: 21 CFR 882.4560 ●
  • Product Code: OLO
  • Regulatory Classification: ● II
  • Device Panel: Orthopedic

Predicate Device

Device Name: StealthStation™ S8 Spine Software v1.3.0 Manufacturer: Medtronic Navigation, Inc. 510(k) Number: K201189

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SpineAR SNAP

Reference Device

Device Name: Surgical Navigation Advanced Platform (SNAP) Manufacturer: Surgical Theater, Inc. 510(k) Number: K160584

Indications for Use:

SpineAR SNAP is intended for use for pre-operative surgical planning on-screen and in a virtual environment, and intra-operative surgical planning and visualization on-screen and in an augmented environment using the HoloLens2 and Magic Leap 1 AR headset displays with validated navigation systems as identified in the device labeling.

SpineAR SNAP is indicated for spinal stereotaxic surgery, and where reference to a rigid anatomical structure, such as the spine, can be identified relative to images of the anatomy. SpineAR is intended for use in spinal implant procedures, such as Pedicle Screw Placement, in the lumbar and thoracic regions with the Magic Leap 1 AR headset, and in the lumbar region with the HoloLens2 AR headset.

The virtual display should not be relied upon solely for absolute positional information and should always be used in conjunction with the displayed 2D stereotaxic information.

Device Description:

The SpineAR SNAP does not require any custom hardware and is a software-based device that runs on a high-performance desktop PC assembled using "commercial off-the-shelf" components that meet minimum performance requirements.

The SpineAR SNAP software transforms 2D medical images into a dynamic interactive 3D scene with multiple point of views for viewing on a high-definition (HD) touch screen monitor. The surgeon prepares a pre-operative plan for stereotaxic spine surgery by inserting guidance objects such as directional markers and virtual screws into the 3D scene. Surgical planning tools and functions are available on-screen and when using a virtual reality (VR) headset. The use of a VR headset for preoperative surgical planning further increases the surgeon's immersion level in the 3D scene by providing a 3D stereoscopic display of the same 3D scene displayed on the touch screen monitor.

By interfacing to a 3rd party navigation system such as a Medtronic StealthStation S8, the SpineAR SNAP extracts the navigation data (i.e. tool position and orientation) and presents the navigation data into the advanced interactive, high quality 3D image, with multiple point of views on a high-definition (HD) touch screen monitor. Once connected, the surgeon can then execute the plan through the intraoperative use of the SpineAR SNAP's enhanced visualization and guidance tools.

The SpineAR SNAP supports three (3) guidance options from which the surgeon selects the level of guidance that will be shown in the 3D scene. The guidance options are dotted line (indicates deviation distance), orientation line (indicates both distance and angular deviation), and ILS (indicates both distance and angular deviation using crosshairs). Visual color-coded cues indicate alignment of the tracker tip to the guidance object (e.g. green = aligned).

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Image /page/5/Picture/0 description: The image shows the logo for Surgical Theater. The logo consists of a stylized letter "S" in red and orange gradient, followed by the words "SURGICAL" in red and "THEATER" in yellow. A registered trademark symbol is next to the word "THEATER". There are two black lines underneath the text.

The 3D scene with guidance tools can also be streamed into an AR wireless headset (Magic Leap 1 or HoloLens2) worn by the surgeon during surgery. The 3D scene and guidance shown within the AR headset is projected above the patient and does not obstruct the surgeons view of the surgical space.

Summary of Technological Characteristics

The SpineAR SNAP is similar in its technological features to its predicate device, the StealthStation S8 Spine Software v1.3.0 (K201189). Both systems are indicated for spinal stereotaxic surgery, and where reference to a rigid anatomical structure, such as the spine, can be identified relative to images of the anatomy.

The SpineAR SNAP does not include any of the physical stereotaxic instrumentation, including camera system, and relies on the positional information supplied by the connected navigation system (e.g. Medtronic StealthStation S8 system with StealthStation Spine Software v1.3.0) to track the position of the surgical instruments relative to the surgical anatomy.

The SpineAR SNAP includes an AR headset that displays the 2D images and 3D scene including navigation and enhanced guidance information in an AR wireless headset (e.g. Microsoft HoloLens2) worn by the surgeon. The predicate device displays 2D and 3D images including navigation information with minimal guidance on a system monitor, and does not support use of AR headset.

FeatureSubject Device:Predicate Device:Reference Device:
SpineAR SNAPStealthStation S8 Spine
Software v1.3.0Surgical Navigation
Advanced Platform (SNAP)
Indications for UseSpineAR SNAP is intended
for use for pre-operative
surgical planning on-screen
and in a virtual environment,
and intra-operative surgical
planning and visualization
on-screen and in an
augmented environment
using the HoloLens2 and
Magic Leap 1 AR headset
displays with validated
navigation systems as
identified in the device
labeling.
SpineAR SNAP is indicated
for spinal stereotaxic
surgery, and where reference
to a rigid anatomical
structure, such as the spine,
can be identified relative to
images of the anatomy.
SpineAR is intended for use
in spinal implant procedures,
such as Pedicle ScrewThe StealthStation™ System,
with StealthStation™ Spine
Software, is intended as an aid
for precisely locating
anatomical structures in either
open or percutaneous
neurosurgical and orthopedic
procedures. Their use is
indicated for any medical
condition in which the use of
stereotaxic surgery may be
appropriate, and where
reference to a rigid anatomical
structure, such as the spine or
pelvis, can be identified
relative to images of the
anatomy.
This can include the following
spinal implant procedures,
such as:
o Pedicle Screw Placement
o Iliosacral Screw Placement
o Interbody Device PlacementThe SNAP is intended for use
as a software interface and
image segmentation system
for the transfer of imaging
information from a medical
scanner such as a CT or MR
scanner to an output file.
It is also intended for use in
simulating and evaluating
surgical treatment options both
pre-operatively and intra-
operatively with validated
systems as identified in the
device labeling.
FeatureSubject Device:
SpineAR SNAPPredicate Device:
StealthStation S8 Spine
Software v1.3.0Reference Device:
Surgical Navigation
Advanced Platform (SNAP)
Placement, in the lumbar and
thoracic regions with the
Magic Leap 1 AR headset,
and in the lumbar region
with the HoloLens2 AR
headset.

The virtual display should
not be relied upon solely for
absolute positional
information and should
always be used in
conjunction with the
displayed 2D stereotaxic
information. | | |
| Main system
components | Cart with computer,
touchscreen monitor,
UPS and input devices. Software application AR Headset VR Headset | Platform including cart,
computer, monitor and
tracking cameras Software application Reflective markers -
Spheres Accessories (Instrument
adaptors, referencing
system) | Cart with computer,
touchscreen monitor and
input devices. Software application VR Headset |
| System Accuracy
Requirements | Provided by the connected
3rd party navigation system
as the subject device does not
include a camera system or
tracking arrays.

Maintains the system
accuracy of the connected
navigation system.

3D positional accuracy with
a mean positional error of
$\le$ 2.0 mm and mean
trajectory error of $\le$ 2
degrees. | Under representative worst-
case Configuration, the
StealthStation S8 Spine
software v1.3.0, has
demonstrated performance in
3D positional accuracy with a
mean positional error of $\le$ 2.0
mm and mean trajectory error
of $\le$ 2 degrees.

Mean Accuracy Values
(StealthAiR Spine):
Positional Error - 1.01 mm
Trajectory Error - 0.37
degrees

Mean Accuracy Values
(Overlapping Slices):
Positional Error - 0.51 mm
Trajectory Error -0.41
degrees | Provided by the connected 3rd
party navigation system as the
subject device does not
include a camera system or
tracking arrays. |
| Imaging Modalities | CT, MR and XA | X-Ray Based Imaging | CT, MR and XA |
| Registration Features | All registration is performed
by the connected 3rd party
navigation system. | PointMerge Registration SurfaceMerge
Registration | All registration is performed
by the connected 3rd party
navigation system. |
| Feature | Subject Device:
SpineAR SNAP | Predicate Device:
StealthStation S8 Spine
Software v1.3.0 | Reference Device:
Surgical Navigation
Advanced Platform (SNAP) |
| Planning Features | Plan Entry and Target
Selection 3D Model Building Directional Markers | Plan Entry and Target
Selection 3D Model Building Deformity Planning | Plan Entry and Target
Selection 3D Model Building |
| Medical Device
Interfaces | The system does not interface
directly with the imaging
modality device. | O-arm Imaging System Ziehm Vision FD Vario
3D C-Arm ISO-C 3D C-Arm Ziehm Vision RFD 3D C-
arm Stealth-Midas MR8 Orbic 3D C-Arm | The system does not interface
directly with the imaging
modality device. |
| Localization
Technology | The subject device does not
include a camera system or
tracking arrays, but instead
relies on the stereotaxic
guidance provided from a
connected 3rd party
navigation system to track
patient anatomy and surgical
tools. | Optical (infra-red) | The subject device does not
include a camera system or
tracking arrays, but instead
relies on the stereotaxic
guidance provided from a
connected 3rd party navigation
system to track patient
anatomy and surgical tools. |
| Connection to 3rd
party surgical
navigation system to
track patient anatomy
and surgical tools. | Yes. Medtronic
StealthStation S8 Spine
Software v1.3.0 | No | Medtronic StealthStation S8
Cranial Version 1.3.0-49 and
Brainlab Cranial Version 2.1 |
| Capability of creating
3D models of patient
data from 2D scan
slices. | Yes | Yes | Yes |
| Virtual Reality (VR)
Headset Display for
Pre-Operative Use | Yes | No | Yes |
| Augmented Reality
(AR) Headset
Display for Intra-
operative Use | Yes | No | No |
| Intra-operative
visualization and
guidance tools shown
on a wireless AR
headset display. | Yes | No | No |
| Feature | Subject Device:
SpineAR SNAP | Predicate Device:
StealthStation S8 Spine
Software v1.3.0 | Reference Device:
Surgical Navigation
Advanced Platform (SNAP) |
| Visual Guidance
Options with color-
coded cues. | 1) Dotted Line
2) Orientation Line
3) ILS | No | No |

The following table compares the key features of the subject and predicate devices:

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Image /page/6/Picture/0 description: The image shows the logo for Surgical Theater. The logo consists of a stylized letter "S" in red and orange gradient, followed by the words "SURGICAL" in red and "THEATER" in yellow. A black line is present under the logo.

SpineAR SNAP

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Image /page/7/Picture/0 description: The image shows the logo for Surgical Theater. The logo consists of a stylized letter "S" in red and orange gradient, followed by the words "SURGICAL" in red and "THEATER" in yellow. A black line is present at the bottom of the logo.

SpineAR SNAP

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Image /page/8/Picture/0 description: The image shows the logo for Surgical Theater. The logo consists of a stylized letter "S" in a gradient of red and orange, followed by the words "SURGICAL" in red and "THEATER" in orange. A black line is present at the bottom of the logo.

The differences between the subject and predicate device do not raise any new questions regarding safety and effectiveness. Based on the information provided in this 510(k) submission. the SpineAR SNAP is considered substantially equivalent to the predicate device in terms of fundamental scientific technology.

Performance Data

The following non-clinical performance testing was conducted to evaluate the subject device to ensure the SpineAR SNAP meets its intended use and performance requirements.

  • Software Verification and Validation was performed to test the software requirements specifications for the SpineAR SNAP.
  • Human Factors and Usability Validation demonstrated that the intended users of a SpineAR SNAP can safely and effectively perform tasks for the intended uses in the expected use environments, i.e. intraoperative use of the AR headsets. Validation took place under conditions of simulated use with users providing feedback on the usability of the software for performing defined tasks.
  • Navigation Accuracy testing was conducted to demonstrate that SpineAR does not negatively affect the navigation accuracy of the connected Medtronic StealthStation 8 surgical navigation system. The final placement of each screw in a spine model was assessed via a post-surgical CT scan and compared to the pre-surgical plan to calculate the absolute displacement of the screw tip and absolute angular error of the screw. The summary of accuracy test results below demonstrate performance in 3D positional and trajectory accuracy that is within the system accuracy of the StealthStation S8 (mean positional error