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510(k) Data Aggregation

    K Number
    K163096
    Date Cleared
    2017-03-31

    (147 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 GPC BRAND Posterior, Non cervical Pedicle Screw Spinal System is intended for use in the noncervical spine. The GPC BRAND Posterior, Non cervical Pedicle Screw Spinal System is used as an adjunct to fusion, using autograft or allograft, in the treatment of the following instabilities and deformities in skeletally mature patients:

    1. Degenerative Disc Disease (DDD, defined as back pain of discogenic origin with degeneration of disc confirmed by history & radiographic studies)
    2. Spondylolisthesis
    3. Trauma (Fracture or Dislocation)
    4. Spinal Stenosis
    5. Scoliosis, Kyphosis and/or lordosis
    6. Pseudoarthrosis
    7. Failed Previous Fusion
      The system is indicated for use in adult patients only. All implants are for single use only.
    Device Description

    The Monoaxial & Polyaxial screw consists of a body, bushing, and ball head screw. Inner Screw, rods and transverse connectors assemblies complete the spinal construct. The body portion of the screw rotates about the ball head on the screw, which provides increased motion over a fixed post or monoaxial screw. An increase in motion facilitates the capture of rods that are not perfectly aligned.
    The Screws, Rods &Transverse Connectors are fabricated from Titanium.
    The system contains several models based on the size of the device and application site such as fixation/reconstruction spine.

    • Single Lock Monoaxial Screw
    • Single Lock Polyaxial Screw
    • Transverse connector
    • Rod
      The diameter of these screw varies from 4mm to 7mm with length 25mm to 50mm.
      The corresponding connector are small & large in size.
      The diameter of Rod is 5.5mm with length 75mm to 150mm
      These implants are supplied non-sterile; the products have to be sterilized prior to use.
    AI/ML Overview

    The document describes a 510(k) premarket notification for the "GPC Brand Posterior, Non cervical Pedicle Screw Spinal System". This type of submission aims to demonstrate that a new device is substantially equivalent to a legally marketed predicate device, and thus does not typically involve extensive clinical studies with specific acceptance criteria as would be found for a novel device requiring a PMA. Instead, the focus is on a comparison to existing devices and adherence to relevant performance standards.

    Based on the provided document, here's a breakdown of the requested information:

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

    The document does not explicitly state "acceptance criteria" in the sense of predefined thresholds for performance metrics. Instead, it relies on demonstrating compliance with recognized industry standards for spinal implants, and equivalence to predicate devices. The "reported device performance" is essentially that the device met these standards and was found equivalent.

    Performance CharacteristicAcceptance Criteria (Standard Reference)Reported Device Performance
    MaterialASTM F136: Standard specification for wrought Titanium-6Aluminium-4Vanadium ELI (Extra low interstitial) Alloy for surgical implant applications.Complied with standard.
    Mechanical PerformanceASTM F1717: Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model.Verified compliance to this standard.
    Indications for UseSimilar to predicate devices (Zodiac Polyaxial Spinal Fixation System (K100685) and Scient'X MX Monoaxial Pedicle Screw System (K042964))Similar intended use, deemed equivalent.
    MaterialSame as predicate devices.Deemed equivalent.
    Performance StandardsSame as predicate devices.Deemed equivalent.
    SterilizationSame method as predicate devices (device is supplied non-sterile and must be sterilized prior to use).Deemed equivalent.
    Dimensional VerificationSame dimensions as predicate devices.Deemed equivalent.

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

    The document refers to "non-clinical testing" performed against ASTM standards. It does not specify a "sample size" in terms of human subjects or a clinical test set. Instead, it refers to mechanical testing of the physical implants. The provenance is internal testing by the manufacturer (GPC Medical Limited) to verify compliance with the standards. This is not a clinical study in humans, but rather laboratory testing of the device components.

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

    This is not applicable to this type of submission. There was no clinical "test set" requiring expert ground truth establishment for diagnostic accuracy or clinical outcomes. The "ground truth" for the non-clinical testing was defined by the ASTM standards themselves (e.g., specific loads, displacement limits).

    4. Adjudication method for the test set

    Not applicable. There was no clinical test set or subjective assessment requiring adjudication.

    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 MRMC study was performed.

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

    Not applicable. This is a spinal implant, not an algorithm.

    7. The type of ground truth used

    For the non-clinical testing, the "ground truth" was defined by the specifications of the referenced ASTM standards (ASTM F136 for material, ASTM F1717 for mechanical performance). These standards provide established methodologies and criteria for evaluating spinal implant constructs. For substantial equivalence, the "ground truth" was the characteristics of the legally marketed predicate devices.

    8. The sample size for the training set

    Not applicable. This device is a physical spinal implant, not an AI or machine learning model that requires a training set.

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

    Not applicable, as there was no training set.

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    K Number
    K143245
    Date Cleared
    2015-09-30

    (322 days)

    Product Code
    Regulation Number
    888.3020
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use
    1. Indication for Use: Multi Angle Tibial Nail is intended to stabilize fracture of the proximal & distal tibia and the tibial shaft, open and closed tibial shaft fractures, certain pre and post isthmic fractures and tibial malunions & nonunions.
    2. Indications for Use: Ga-mma Nail is indicated for use in stabilizing various types of intertrochanteric fractures of proximal femur.
    Device Description

    The GPC Intramedullary Nailing Systems include intramedullary nails and corresponding screws/end caps/locking bolts for fastening these intramedullary nails to the fractured bones.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for "GPC Intramedullary Nailing Systems". This submission demonstrates substantial equivalence to predicate devices based on non-clinical testing and comparison of characteristics, rather than a clinical effectiveness study involving human subjects or an AI standalone or AI-assisted performance evaluation.

    Therefore, many of the requested categories regarding acceptance criteria for AI performance, clinical study details, and expert involvement are not applicable to this document.

    Here's a breakdown of the information that is available and the information that is not.

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

    The acceptance criteria are implicitly defined by compliance with the given material and performance standards, and comparison to the predicate devices. The "reported device performance" is framed as demonstrating equivalence to the predicate devices in these areas rather than specific quantitative performance metrics against a defined threshold.

    Acceptance Criteria CategoryDevice Performance (vs. Predicate Device)Remarks
    Multi Angle Tibial Nail
    Indications for UseSame intended useEquivalent
    MaterialSame material (also available in Stainless Steel type)Equivalent
    Performance StandardsSame performance standardsEquivalent
    SterilizationSame method of sterilizationEquivalent
    Dimensional VerificationDifferences in geometry do not affect safety; performance test results indicate equivalenceEquivalent
    ASTM F 136 Material StandardComplied
    ASTM F 138 Material StandardComplied
    ASTM F 1264 PerformanceComplied; relevant test results comparing subject devices with predicate devices in Executive Summary (not provided here)
    Ga-mma Nail
    Indications for UseSame intended useEquivalent
    MaterialSame materialEquivalent
    Performance StandardsSame performance standardsEquivalent
    SterilizationSame method of sterilizationEquivalent
    Dimensional VerificationEnd cap with collar prevents sharp edges, adds strength and safety; does not lead to safety concerns related to device performanceEquivalent
    ASTM F 136 Material StandardComplied
    ASTM F 138 Material StandardComplied
    ASTM F 384 PerformanceComplied; relevant test results comparing subject devices with predicate devices in Executive Summary (not provided here)

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

    Not applicable. This submission relies on non-clinical (bench) testing and comparison to predicate devices, not a test set of patient data, retrospective or prospective.

    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. This submission does not involve ground truth assessment by experts in the context of a test set for clinical performance. The "ground truth" for equivalence is established by compliance with engineering and material standards and direct comparison of specifications and bench testing results to the predicate devices.

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

    Not applicable. There is no test set for clinical performance or adjudication process described.

    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 not an AI/software device and no MRMC study was conducted.

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

    Not applicable. This is a medical device (intramedullary nailing systems), not an algorithm or software. Its performance is assessed through material and bench testing.

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

    The "ground truth" for this device's performance is established by:

    • Compliance with material standards (ASTM F 136, ASTM F 138).
    • Compliance with performance standards (ASTM F 1264 for Tibial Nail, ASTM F 384 for Ga-mma Nail).
    • Demonstration of equivalence in physical characteristics (dimensions, materials) and intended use compared to legally marketed predicate devices.
    • The results of non-clinical (bench) testing showing comparable performance to the predicate devices (as detailed in the "executive summary" which is not fully provided here, but referenced).

    8. The sample size for the training set

    Not applicable. This is not an AI/machine learning device.

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

    Not applicable. This is not an AI/machine learning device.

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