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510(k) Data Aggregation

    K Number
    K193270
    Date Cleared
    2020-01-31

    (66 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CapLOX II® / TowerLOX® MIS Pedicle Screw System is a posterior, non-cervical pedicle fixation system 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 including degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, scoliosis, kyphosis, spinal tumor, pseudarthrosis and failed previous fusion.

    In addition, when used as a pedicle screw fixation system, the CapLOX II® / TowerLOX® MIS Pedicle Screw System is intended for skeletally mature patients with severe spondylolisthesis (Grades 3 and 4) of the fifth lumbar-first sacral, L5-S1 vertebra, who are receiving fusion by autogenous bone graft only, who are having the device attached to the lumbar and sacral spine (levels may be from L3 to the sacrum/ilum), who are having the device removed after the attainment of a solid fusion.

    Device Description

    The CapLOX II® / TowerLOX® MIS Pedicle 4.5mm Screw System is an implant device made from a titanium alloy Ti-6Al-4V ELI per ASTM F136. It is to be implanted from the posterior approach. The screws are currently available in diameters from 4.9-9.0mm and in lengths frOm 30-100mm. The line extension will include the addition of 4.5mm screws for the CapLOX II® /TowerLOX® MIS Pedicle Screw System in lengths of 30-55mm. Additional instrumentation will also be added to the system. Overall, the system includes pedicle screws, and the instrumentation in order to complete the procedure and implant construct when performed using minimally invasive surgical techniques.

    AI/ML Overview

    The provided document is a 510(k) premarket notification letter and summary for a medical device, specifically the CapLOX II® / TowerLOX® MIS Pedicle Screw System. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving performance against specific acceptance criteria through a clinical trial or a standalone study as might be seen for novel devices or AI/software products requiring such validation.

    Therefore, the information requested in the prompt, such as detailed acceptance criteria, sample sizes for test/training sets, expert qualifications, and adjudication methods for AI performance, is not applicable to this document. This submission pertains to a mechanical implant (pedicle screw system) and its line extension (adding a 4.5mm screw and instrumentation). The "study" referenced in the document is primarily mechanical testing and engineering analysis to demonstrate that the new components perform equivalently to the predicate device and do not introduce new safety concerns.

    Here's an attempt to address the prompt based only on the information available in the provided text, highlighting where the requested details are not present due to the nature of the device and submission:

    Acceptance Criteria and Device Performance for Captiva Spine, Inc.'s CapLOX II® / TowerLOX® MIS Pedicle Screw System (K193270)

    The device in question is a mechanical implant (pedicle screw system), and its 510(k) submission aims to demonstrate substantial equivalence to a predicate device, not necessarily to meet pre-defined acceptance criteria for a diagnostic or AI-driven system. The "acceptance criteria" here relate to demonstrating equivalence in mechanical performance.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Proxy: Demonstration of Equivalence to Predicate)Reported Device Performance
    No new "worst case" introduced compared to predicate devices.Engineering Analysis and Dynamic Compression Bending testing per ASTM F1717 were conducted. Results confirmed that the 4.5mm pedicle screws perform equivalently to the predicate data and do not introduce a new "worst case" implant.
    Similar Indications for Use.Identical to predicate device.
    Similar Materials of manufacture.Identical to predicate device (titanium alloy Ti-6Al-4V ELI per ASTM F136).
    Similar Structural support mechanism.Identical to predicate device.
    No new safety or effectiveness concerns.Assessed and concluded that minor differences do not raise any new safety and effectiveness issues. Risk management techniques confirmed no new worst cases. Overall technology characteristics lead to the conclusion of substantial equivalence.

    2. Sample size used for the test set and the data provenance

    • Sample Size: The document does not specify a "sample size" in the context of a clinical test set. The evaluation was primarily through mechanical testing (Dynamic Compression Bending testing per ASTM F1717). For such tests, the "sample size" would typically refer to the number of physical devices or components tested, which is not detailed in this summary.
    • Data Provenance: Not applicable in the context of clinical data. The performance data is derived from benchtop mechanical testing. The origin would be the testing facility where the ASTM F1717 tests were performed. This is not retrospective or prospective clinical data.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    • Number of Experts & Qualifications: Not applicable. Ground truth, in the sense of clinical diagnoses or interpretations, is not established for this type of mechanical device submission. The "ground truth" for mechanical testing is adherence to established engineering standards and material properties, evaluated by engineers.

    4. Adjudication method for the test set

    • Adjudication Method: Not applicable. There is no clinical test set requiring adjudication in this submission. Mechanical testing results are typically evaluated against pre-defined engineering specifications.

    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

    • MRMC Study: No. This device is a pedicle screw system, not an AI or diagnostic imaging device that would involve human readers or AI assistance in interpretation.

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

    • Standalone Performance: No. This device is a physical implant, not an algorithm or software.

    7. The type of ground truth used

    • Type of Ground Truth: For the mechanical testing, the "ground truth" is defined by established engineering standards and material science properties (e.g., ASTM F1717 for mechanical performance, ASTM F136 for material composition). The objective is to demonstrate that the device meets these standards and performs comparably to the predicate.

    8. The sample size for the training set

    • Training Set Sample Size: Not applicable. This is not a machine learning or AI device that would utilize a training set.

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

    • Training Set Ground Truth Establishment: Not applicable, as there is no training set for this device.
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    K Number
    K181229
    Date Cleared
    2018-09-19

    (133 days)

    Product Code
    Regulation Number
    888.3080
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Captiva Spine TirboLOX-C™ Cervical IBFD is indicated for use in skeletally mature patients with degenerative disc disease (DDD) of the cervical spine at one-disc level. DDD is defined as neck pain of discogenic origin with the degeneration of the disc confirmed by history and radiographic studies. The Captiva Spine TirboLOX-C™ Cervical IBFD is used to facilitate fusion in the cervical spine and is placed via an anterior approach at the C3 to C7 disc levels with autograft bone and/or allogenic bone graft composed of cancellous bone graft. Patients should have at least six weeks of non-operative to treatment with an intervertebral body fusion device. The device must be used with supplemental fixation.

    Device Description

    The Captiva Spine, Inc. TirboLOX-CTM Cervical IBFD is made from a titanium alloy and is created using 3D printing technologies. The implants are available in various footprints to accommodate a variety of patient anatomies and is provided sterile. The device has a window in the center of device to accept autogenous bone and/or allogenic bone graft. The implant is available in the following configurations: lordotic, anatomically correct and parallel

    AI/ML Overview

    This is a 510(k) premarket notification for a medical device, not a study evaluating an AI algorithm. Therefore, the requested information about acceptance criteria, study data, ground truth, and AI performance metrics is not applicable here.

    The document describes the Captiva Spine TirboLOX-C™ Cervical IBFD, an intervertebral body fusion device. It focuses on demonstrating the device's substantial equivalence to legally marketed predicate devices through a series of non-clinical mechanical tests.

    Here's a breakdown of the relevant information present in the document:

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

    The document does not provide a table with specific quantitative acceptance criteria alongside performance data. Instead, it states that "The results of this non-clinical testing show that the strength of the TirboLOX-C™ Cervical IBFD is sufficient for its intended use and is substantially equivalent to legally marketed predicate devices." This implies that the device's performance in the listed tests met predetermined criteria acceptable for demonstrating equivalence to the predicate devices, but the exact numerical thresholds are not disclosed.

    Device Performance (as reported):

    • ASTM F2077-14: Static Axial Compression, Static Shear, Static Torsion, Dynamic Axial Compression, Dynamic Shear, Dynamic Torsion
    • ASTM 2267-04: Static Subsidence
    • ASTM F1978-12: Abrasion Resistance
    • ASTM F1877-16: Wear Debris
    • Additionally: Expulsion testing was performed.

    The reported performance is qualitative: the device's strength is sufficient for its intended use and substantially equivalent to predicate devices. Specific quantitative results are not provided in this summary document.

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

    This information is not provided because it's a mechanical device testing, not a clinical study on human data. The "sample" would refer to the number of devices tested, which is not specified. Data provenance like country of origin or retrospective/prospective is not relevant for this type of non-clinical, in-vitro testing.

    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. Ground truth as typically defined for AI/medical imaging studies (e.g., expert consensus on diagnoses) is not relevant for mechanical device testing. The "ground truth" for these tests are the established standards and specifications of the ASTM methods.

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

    Not applicable. Adjudication methods are used in clinical trials or expert reviews to resolve disagreements in interpretations, which is not part of mechanical testing.

    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 spinal implant, not an AI-powered diagnostic device. No human readers or AI assistance were involved in the testing described in this document.

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

    Not applicable. This device is an implant, not an algorithm.

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

    The "ground truth" for the mechanical performance tests are the established ASTM (American Society for Testing and Materials) standards and test methodologies. These standards define the parameters, procedures, and conditions for evaluating the mechanical properties of medical implants to ensure their safety and effectiveness. The goal is to show the device performs within acceptable limits mandated by these standards and comparably to predicate devices.

    8. The sample size for the training set

    Not applicable. There is no AI algorithm being described, so there is no training set.

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

    Not applicable, as there is no training set.

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    K Number
    K180990
    Date Cleared
    2018-08-13

    (119 days)

    Product Code
    Regulation Number
    888.3080
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Captiva Spine, Inc. TirboLOX-L™ Lumbar IBFD is indicated for use in skeletally mature patients with Degenerative Disc Disease (DDD) at one or two contiguous levels from L2-S1. DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies. Patients should have received 6 months of non-operative treatment prior to treatment with the devices. The device must be used with supplemental fixation and must be used with autograft and/or allogenic bone graft comprised of cancellous and/or corticocancellous bone graft. The DDD patients may also have up to a Grade I spondylolisthesis or retrolisthesis at the involved level(s).

    Device Description

    The Captiva Spine, Inc. TirboLOX-L™ Lumbar IBFD is made from a titanium alloy (Ti-6Al-4V ELI per ASTM F3001 and TI-6Al-4V ELI per ASTM F136) and is created using 3D printing technologies. The implants are available in various footprints to accommodate a variety of patient anatomies and is provided sterile. The device has a window in the center of device to accept autogenous bone and/or allogenic bone graft. The implant is available in the following configurations: PLIF (Lordotic; 3°, 6°, and 15°, Convex) and TLIF (Straight, Curved Lordotic and Curved Parallel)

    AI/ML Overview

    This document describes the regulatory clearance for a medical device and, as such, does not contain information about acceptance criteria or a study proving a device meets them in the way described in your request.

    The provided text is a 510(k) summary for the TirboLOX-L™ Lumbar IBFD, an intervertebral body fusion device. Its purpose is to demonstrate substantial equivalence to legally marketed predicate devices, not to establish performance against acceptance criteria in the context of an AI/software as a medical device (SaMD) evaluation.

    Therefore, I cannot extract the following information as it is not present in the provided document:

    • A table of acceptance criteria and reported device performance.
    • Sample size used for the test set and data provenance.
    • Number of experts used to establish ground truth and their qualifications.
    • Adjudication method for the test set.
    • Whether a multi-reader multi-case (MRMC) comparative effectiveness study was done, or the effect size of human readers improving with AI vs. without AI assistance.
    • Whether a standalone (algorithm only) performance study was done.
    • The type of ground truth used (expert consensus, pathology, outcomes data, etc.).
    • The sample size for the training set.
    • How the ground truth for the training set was established.

    What the document does describe in terms of "performance data" is the results of non-clinical, mechanical testing to ensure the structural integrity and biocompatibility of the physical implant.

    Here's the relevant section from the document concerning "Performance Data":

    Performance Data:
    The TirboLOX-L™ Lumbar IBFD has been tested in the following test modes:

    • ASTM F2177-14 Static Axial Compression
    • Static Shear
    • Dynamic Axial Compression
    • Dynamic Shear
    • ASTM 3267-04 Static Subsidence
    • AAMI ST72 Bacterial Endotoxin Testing

    Additionally, expulsion testing was performed. The results of this non-clinical testing show that the strength of the TirboLOX-L™ Lumbar IBFD is sufficient for its intended use and is substantially equivalent to legally marketed predicate devices.

    This information relates to the physical characteristics and safety of the implant itself, not to the performance of a diagnostic or therapeutic algorithm.

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    K Number
    K180475
    Date Cleared
    2018-03-19

    (25 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CapLOX II® / TowerLOX® Pedicle Screw System is a posterior, non-cervical pedicle fixation system 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 including degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, scoliosis, kyphosis, spinal tumor, pseudarthrosis and failed previous fusion.

    In addition, when used as a pedicle screw fixation system, the CapLOX II® / TowerLOX® Pedicle Screw System is intended for skeletally mature patients with severe spondylolisthesis (Grades 3 and 4) of the fifth lumbar-first sacral, L5-S1 vertebra, who are receiving fusion by autogenous bone graft only, who are having the device attached to the lumbar and sacral spine (levels may be from L3 to the sacrum/ilum), who are having the device removed after the attainment of a solid fusion.

    Device Description

    The CapLOX II® / TowerLOX® MIS Pedicle Screw System is an implant device made from a titanium alloy Ti-6Al-4V ELI per ASTM F136. It is to be implanted from the posterior approach. The screws are currently available in diameters from 4.9-9.0mm and in lengths from 30-100mm. The line extension will include the addition of 4.9-9.0mm extended tab screws to be marketed as TowerLOX® EXT MIS Extended Tab Pedicle Screws in lengths of 30-100mm. All screws with a 5.5mm, 6.5mm and 7.5mm screw diameters will have an updated tip angle. The set screws currently have a 5mm hex, will also be available with a T25 Torx interface. Additional instrumentation will also be added to the system. Overall, the system includes set screws, pedicle screws, and rods with the associated instrumentation in order to complete the procedure and implant construct when performed using minimally invasive surgical techniques.

    AI/ML Overview

    This FDA 510(k) premarket notification describes the CapLOX II® / TowerLOX® MIS Pedicle Screw System, a pedicle screw system, as a line extension. This means it is based on a previously cleared predicate device (CapLOX II® / TowerLOX® Pedicle Screw System, K131538). The submission focuses on demonstrating substantial equivalence to this predicate device by highlighting that the new components do not introduce new safety or effectiveness concerns.

    Here's an analysis of the provided information concerning acceptance criteria and the study that proves the device meets them:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state quantitative "acceptance criteria" in the format of a table with numerical goals and reported performance values. Instead, it relies on demonstrating substantial equivalence to a predicate device. The primary "performance" reported is that the modifications (extended tab pedicle screws, updated screw tip angle, additional set screw interface) do not create a new worst case when compared against the predicate devices and were concluded as not raising any new issues for safety and effectiveness. This implies that the device performs at least as well as the predicate device in terms of safety and effectiveness.

    The document highlights the following similarities and an implied performance level:

    Acceptance Criterion (Implied)Reported Device Performance
    Materials of manufactureIdentical (titanium alloy Ti-6Al-4V ELI per ASTM F136) to predicate
    Structural support mechanismIdentical to predicate
    Indications for UseIdentical to predicate
    No new worst caseModifications assessed using risk management and concluded not to create a new worst case
    No new safety/effectiveness issuesAssessed and concluded not to raise any new issues for safety and effectiveness

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not describe a "test set" in the context of clinical data for evaluating the device's performance. This submission is for a line extension of a medical device, and the evaluation relies on demonstrating that the new components are substantially equivalent to the previously cleared predicate device. This typically involves non-clinical performance testing (e.g., mechanical, material characterization) rather than a clinical study with a patient "test set". Therefore, information regarding sample size, country of origin, or retrospective/prospective nature for a clinical test set is not applicable here.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    Since there is no "test set" in a clinical context as described above, this information is not applicable. The "ground truth" for this type of submission largely rests on compliance with established material and mechanical standards, and engineering analysis comparing the new components to the predicate. Internal engineering experts and regulatory affairs personnel within Captiva Spine, Inc. would have been involved in this assessment.

    4. Adjudication Method for the Test Set

    As there is no clinical "test set" described, an adjudication method is not applicable.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size

    No, an MRMC comparative effectiveness study was not done. This type of study is relevant for evaluating the performance of diagnostic or AI-assisted devices where human readers interpret medical images or data. The CapLOX II® / TowerLOX® MIS Pedicle Screw System is an implantable surgical device, and its evaluation does not involve human readers interpreting data in this manner.

    6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done

    No, a standalone (algorithm only) performance study was not done. This concept is relevant for AI/ML-driven devices. This submission concerns a physical implantable device, not an algorithm.

    7. The Type of Ground Truth Used

    The "ground truth" for this submission is based on:

    • Material properties data: Conformance to ASTM F136 for titanium alloy Ti-6Al-4V ELI.
    • Mechanical testing data: Implied by the statement "These modifications have been assessed using risk management techniques and were concluded as not creating a new worst case when compared against the predicate devices." This typically involves bench testing (e.g., fatigue, static strength) to ensure the new components meet or exceed the performance characteristics of the predicate.
    • Engineering analysis: Comparing the design and function of the new extended tab screws, updated tip angle, and set screw interfaces to the predicate device to determine that no new safety or effectiveness concerns are introduced.

    8. The Sample Size for the Training Set

    There is no "training set" in the context of this device submission. This refers to data used to train AI models, which is not applicable here.

    9. How the Ground Truth for the Training Set Was Established

    As there is no "training set," this question is not applicable.

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