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510(k) Data Aggregation
(84 days)
CROSS MEDICAL PRODUCTS, INC.
As a pedicle screw system, it is intended only for patients: (a) having severe spondylolisthesis (Grades 3 and 4) of the fifth lumbar-first sacral (L5-S1) vertebral joint; (b) who are receiving fusions using autogenous bone graft only; © who are having the screws fixed or attached to the lumbar and sacral spine; and (d) who are having the device removed after the development of a solid fusion mass. The levels of screw fixation are L3 to S1/Ilium.
As a posterior, non-pedicle screw and hook system, and an anterolateral, intervertebral body screw system, the specific indications are:
- Degenerative Disc Disease (as defined by chronic back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies).
- Idiopathic scoliosis.
- Kyphotic deformities of the spine.
- Paralytic scoliosis and/or pelvic obliquity.
- Lordotic deformities of the spine.
- Neuromuscular scoliosis associated with pelvic obliquity.
- Vertebral fracture or dislocation.
- Tumors.
- Spondylolisthesis.
- Stenosis.
- Pseudarthrosis.
- Unsuccessful previous attempts at spinal fusion.
For posterior, non-pedicle screw use, the levels of use are T1 to the Sacrum/Ilium. For anterior use, the levels of use are T10 to L3 for the double rod constructs, and T5 to L5 for the single rod constructs.
The SYNERGY™ Spinal System is intended to be used a part of a temporary construct that assists normal healing and is not intended to replace normal body structures. It is intended to help stabilize the spinal operative site during fusion procedures. It attaches to the spine posteriorly by means of hooks and/or screws joined with rods and anteriorly by means of vertebral screws joined with rods.
The posterior application components are grouped as follows:
- INTEGRAL TM Open, Closed, Angled Closed and Reduction Screws, Variable Locking Screws with Variable Locking Seats, and Iliac Screws, with Hex Nuts and Set Screws. Only the INTEGRALTM Open, Closed, Reduction and Variable Locking Screws are intended for pedicle fixation (see INDICATIONS).
- Open and Closed Spinal Hooks with Sliders, C-Rings and Set Screws.
- Adjustable and Fixed Transverse connectors with Set Screws.
- Closed and Axial Rod Connectors with Set Screws.
- Lateral Connectors with Set Screws.
- Rods.
- Instruments.
- Sterilizer case(s).
The anterior application components are grouped as follows:
- INTEGRAL™ Open and Closed Screws and Variable Locking Screws with Variable Locking Seats, with Hex Nuts and Set Screws.
- Vertebral Washers.
- Fixed Transverse Connectors with Set Screws.
- Rods.
- Instruments.
- Sterilizer case(s).
Material: The implantable components may be made from either titanium or stainless steel. The titanium version consists of surgical implant grade titanium alloy as described by ASTM Standard F136 (Ti 6A1-4V ELI), and commercially pure titanium, grade 2 as described by ASTM Standard F67 (CP Ti, Gr. 2). The stainless steel version consists of surgical implant grade stainless steel as described by ASTM standard F1314 (22-13-5 Stainless Steel), and surgical implant grade stainless steel as described by ASTM standard F138, Grade 2 (316L Stainless Steel).
The provided text is a 510(k) Summary and FDA clearance letter for the SYNERGY™ Spinal System- Closed VLS™. It describes the device, its indications, and substantial equivalence to previously cleared devices. However, this document does not contain information about acceptance criteria or a specific study proving the device meets those criteria in the way a diagnostic or AI/ML device would.
Instead, the submission for this spinal implant system focuses on demonstrating substantial equivalence to predicate devices. This typically involves showing that the new device has the same intended use, similar technological characteristics, and raises no new questions of safety or effectiveness compared to a legally marketed predicate device. This is often achieved through engineering analysis, material certifications, and adherence to voluntary performance standards (like ASTM standards for materials) rather than clinical studies with defined acceptance criteria for diagnostic performance metrics.
Since the document does not present acceptance criteria or a study proving the device meets them in the context of diagnostic performance, I cannot fill in the requested table and answer the study-related questions.
Here's a breakdown of why the specific information requested is not present in this type of document:
- Type of Device: This is a spinal implant, a physical medical device for structural support, not a diagnostic or AI/ML product. The regulatory pathway for such devices focuses on bio-compatibility, mechanical integrity, and surgical utility.
- Regulatory Pathway: A 510(k) submission for substantial equivalence generally does not require prospective clinical trials with predefined performance metrics and acceptance criteria like those needed for novel diagnostic devices or pharmaceuticals. The "study" here refers to the engineering analysis and material testing to confirm the device's physical properties are comparable to existing, cleared devices.
- "Acceptance Criteria": For this type of device, "acceptance criteria" would relate to manufacturing quality, material specifications, and mechanical strength testing (e.g., fatigue strength, pull-out strength). These are implied by the use of ASTM standards and in-house SOPs, but specific numerical targets and measured performance data from a single comprehensive study are not typically summarized in the 510(k) summary provided.
- "Reported Device Performance": This would be in terms of its ability to stabilize the spine and the biomechanical integrity of the components, which is implicitly demonstrated through comparison to predicate devices and adherence to material/design standards.
- Clinical Studies (MRMC, Standalone): These are usually relevant for diagnostic devices that produce an output (e.g., an image interpretation, a risk score) that needs to be evaluated against a ground truth. For implants, the "performance" is its physical function in the body.
- Ground Truth: For implants, "ground truth" might relate to successful fusion rates or long-term structural integrity, but these are typically outcomes studied in post-market surveillance or larger clinical trials, not usually part of a 510(k) for substantial equivalence.
- Sample Size (Test/Training Set), Data Provenance, Experts, Adjudication: These terms are applicable to studies validating diagnostic or AI/ML algorithms, not the mechanical and material properties of a spinal implant.
Therefore, I must state that the provided text does not contain the information necessary to fulfill the request as formatted, because the device and regulatory submission type do not align with the questions asked.
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(148 days)
CROSS MEDICAL PRODUCTS, INC.
As a pedicle screw system, it is intended only for patients: (a) having severe spondylolisthesis (Grades 3 and 4) of the fifth lumbar-first sacral (L5-S1) vertebral joint; (b) who are receiving fusions using autogenous bone graft only; © who are having the screws fixed or attached to the lumbar and sacral spine; and (d) who are having the device removed after the development of a solid fusion mass. The levels of screw fixation are L3 to S1/Ilium.
As a posterior, non-pedicle screw and hook system, and an anterolateral, intervertebral body screw system, the specific indications are:
- Degenerative Disc Disease (as defined by chronic back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies).
- Idiopathic scoliosis.
- Kyphotic deformities of the spine.
- Paralytic scoliosis and/or pelvic obliquity.
- Lordotic deformities of the spine.
- Neuromuscular scoliosis associated with pelvic obliquity.
- Vertebral fracture or dislocation.
- Tumors.
- Spondylolisthesis.
- Stenosis.
- Pseudarthrosis.
- Unsuccessful previous attempts at spinal fusion.
For posterior, non-pedicle screw use, the levels of use are T1 to the Sacrum/Ilium. For anterior use, the levels of use are T10 to L3 for the double rod constructs, and T5 to L5 for the single rod constructs.
The SYNERGY™ Spinal System is intended to be used a part of a temporary construct that assists normal healing and is not intended to replace normal body structures. It is intended to help stabilize the spinal operative site during fusion procedures. It attaches to the spine posteriorly by means of hooks and/or screws joined with rods and anteriorly by means of vertebral screws joined with rods.
The posterior application components are grouped as follows:
- INTEGRALTM Open, Closed, Angled Closed and Reduction Screws, Variable Locking Screws with Variable Locking Seats, and Iliac Screws, with Hex Nuts and Set Screws. Only the INTEGRALTM Open, Closed, Reduction and Variable Locking Screws are intended for pedicle fixation (see INDICATIONS).
- Open and Closed Spinal Hooks with Sliders, C-Rings and Set Screws.
- Adjustable and Fixed Transverse connectors with Set Screws.
- Closed and Axial Rod Connectors with Set Screws.
- Lateral Connectors with Set Screws.
- Rods.
- Instruments.
- Sterilizer case(s).
The anterior application components are grouped as follows:
- INTEGRAL™ Open and Closed Screws and Variable Locking Screws with Variable Locking Seats, with Hex Nuts and Set Screws.
- Vertebral Washers.
- Fixed Transverse Connectors with Set Screws.
- Rods.
- Instruments.
- Sterilizer case(s).
Material: The implantable components may be made from either titanium or stainless steel. The titanium version consists of surgical implant grade titanium alloy as described by ASTM Standard F136 (Ti 6A1-4V ELI), and commercially pure titanium, grade 2 as described by ASTM Standard F67 (CP Ti, Gr. 2). The stainless steel version consists of surgical implant grade stainless steel as described by ASTM standard F1314 (22-13-5 Stainless Steel), and surgical implant grade stainless steel as described by ASTM standard F138, Grade 2 (316L Stainless Steel).
The provided document is a 510(k) Summary for a medical device (SYNERGY™ Spinal System-Additional Components), which is a premarket notification to the FDA to demonstrate that the device is substantially equivalent to a legally marketed predicate device. This type of submission relies on demonstrating equivalence rather than proving performance against specific acceptance criteria through clinical studies. Therefore, the document does not describe, nor does it require, a standalone study to prove the device meets acceptance criteria in the way a clinical trial or performance study for a novel device would.
Instead, the "acceptance criteria" here are implied by the standards and regulations used to demonstrate substantial equivalence, and the "study" is the overall submission process that compares the new device to existing ones.
Here's a breakdown based on the provided document, addressing your questions with relevant information or stating when the information is not applicable:
1. Table of Acceptance Criteria and Reported Device Performance
As mentioned, this document is a 510(k) summary, not a clinical trial report. Thus, there isn't a table of discrete acceptance criteria and direct device performance metrics from a study in the traditional sense. The "acceptance criteria" are compliance with regulatory requirements and demonstration of substantial equivalence. The "device performance" is established by showing it possesses similar characteristics and safety/effectiveness profiles to predicate devices, and through mechanical testing (mentioned but not detailed).
Acceptance Criteria (Implied by 510(k) Process) | Reported Device Performance (Summary from Document) |
---|---|
Substantial Equivalence to Predicate Devices | The SYNERGY™ Spinal System-Additional Components are declared substantially equivalent to the SYNERGY™ Anterior and Posterior, Stainless Steel and Titanium Spinal System (cleared under K934429, K940631, K950099, and K950709). |
Similar Indications for Use | Devices are used to treat "similar or the same conditions." |
Equivalent Cautions and Contraindications | Devices have "essentially the same cautions and contraindications for use." |
Equivalent Potential for Complications/Risk | Devices have "equivalent potential for complications for risk of use." |
Basic Design Concept | The device represents "a long standing, basic design concept." |
Material Standards Compliance | Implantable components comply with ASTM Standard F136 (Ti 6A1-4V ELI), ASTM Standard F67 (CP Ti, Gr. 2), ASTM standard F1314 (22-13-5 Stainless Steel), and ASTM standard F138, Grade 2 (316L Stainless Steel). Instruments comply with ASTM A276, ASTM A564/A564M, and ASTM F899 standards. |
Sterilization Protocol Validation | High temperature steam sterilization cycle (Gravity, 250°F (121°C), 60 minutes) was "laboratory validated" based on HIMA/AORN protocols. |
Mechanical Testing | "Mechanical testing" was performed (mentioned in conclusion, but no details provided). |
Compliance with General Controls (GMP, Labeling, etc.) | Implied compliance with current Good Manufacturing Practice (GMP) requirements, annual registration, listing of devices, labeling, and prohibitions against misbranding and adulteration. This is a condition of market clearance. |
2. Sample Size Used for the Test Set and the Data Provenance
- Not Applicable. This document describes a 510(k) submission for mechanical spinal implants, not a study involving a "test set" of patient data or samples to evaluate AI/software performance. The "test set" in this context would refer to the device components undergoing various engineering and material tests, but specific sample sizes and data provenance for these are not detailed in this summary.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
- Not Applicable. As above, this is a mechanical device submission, not a study requiring expert-established ground truth for a test set in the clinical or AI sense. The "experts" involved would be regulatory reviewers at the FDA and potentially engineers and scientists employed by Cross Medical Products, Inc. who perform the material and mechanical testing.
4. Adjudication Method for the Test Set
- Not Applicable. No test set or related adjudication method is described in this 510(k) summary. Decisions regarding the substantial equivalence are made by the FDA based on the provided evidence.
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
- Not Applicable. This is a physical spinal implant, not an AI or diagnostic imaging device that would involve human readers or AI assistance.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not Applicable. This is a physical spinal implant, not an algorithm.
7. The Type of Ground Truth Used
- Not Applicable in the traditional sense of a clinical study. For this medical device, "ground truth" would relate to the accepted engineering standards for materials (e.g., ASTM standards: F136, F67, F1314, F138, A276, A564/A564M, F899) and the "laboratory validated" sterilization protocols (HIMA/AORN protocols). Additionally, the performance of the predicate devices serves as a "ground truth" for demonstrating substantial equivalence.
8. The Sample Size for the Training Set
- Not Applicable. This document does not describe a machine learning algorithm or a "training set."
9. How the Ground Truth for the Training Set Was Established
- Not Applicable. No training set is involved.
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