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510(k) Data Aggregation

    K Number
    K151362
    Device Name
    HC Spinal System
    Date Cleared
    2016-05-05

    (350 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 HC Spinal System is intended for posterior noncervical pedicle fixation as an adjunct to fusion in skeletally mature patients for the following indications: severe spondylolisthesis (i.e., Grades 3 and 4 at L5-S1 or degenerative spondylolisthesis with objective evidence of neurologic impairment), trauma (i.e., fracture or dislocation), spinal stenosis, curvatures (i.e., scoliosis, and/or lordosis), tumor, pseudoarthrosis and failed previous fusion.

    Device Description

    The HC Spinal System offers a comprehensive solution for immobilizing and stabilizing spinal deformities in patients as an adjunct to fusion. The HC Spinal System consists of monoaxial and polyaxial pedicle screws, set screw and rods. The components are available in a variety of diameters and lengths in order to accommodate patient anatomy and are fabricated from titanium alloy. The implants will be provided non-sterile and will be used for either posterior or anterolateral non cervical fixation.

    AI/ML Overview

    The provided text is a 510(k) summary for the HC Spinal System, a medical device. It does not describe a study involving an AI algorithm or human-in-the-loop performance. Instead, it details the non-clinical testing performed on a physical spinal implant system to demonstrate its substantial equivalence to a predicate device.

    Therefore, most of the requested information regarding AI performance, sample sizes for test/training sets in an AI context, expert ground truth, adjudication methods, and MRMC studies is not applicable to this document.

    Here's the relevant information that can be extracted:

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

    The document states that a series of non-clinical tests were performed. The "reported device performance" is a general statement that the device met the requirements. Specific numerical acceptance criteria and performance values are not provided in this summary.

    Acceptance Criteria (General)Reported Device Performance
    Meeting requirements of pre-defined acceptance criteria (implied by test standards)All test results demonstrate that HC Spinal system meets the requirements of its pre-defined acceptance criteria and intended uses.
    Compliance with ASTM F1717 for PerformanceComplied with ASTM F1717

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

    • Sample sizes for test set: Not specified in the document. The tests performed are engineering/materials tests on physical devices, not clinical studies with human participants.
    • Data provenance: Taiwan (R.O.C.) (where the submitter is located), for the device manufacturing/testing.

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

    Not applicable. The "ground truth" for this type of device (spinal implant) is established through engineering and material testing standards (e.g., ASTM F1717). No human expert consensus for a "test set" in the context of interpretation of medical data is described.

    4. Adjudication method for the test set

    Not applicable. This is not a study requiring adjudication of interpretations.

    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 document does not describe an AI device or an MRMC study.

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

    Not applicable. This document does not describe an AI algorithm.

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

    The "ground truth" or standard for evaluation is based on pre-defined acceptance criteria derived from established engineering and material testing standards, such as ASTM F1717 for mechanical performance, and general biological safety standards for cytotoxicity, irritation, etc. These are objective measures rather than expert consensus on medical image interpretation or pathology.

    8. The sample size for the training set

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

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

    Not applicable. There is no AI algorithm, so no training set or associated ground truth establishment.

    Summary of the study that proves the device meets the acceptance criteria:

    The study described is a series of non-clinical tests performed on the HC Spinal System. These tests are outlined in Section 8 ("Non-clinical Testing") and include:

    • Shelf Life Test
    • In vitro Cytotoxicity Test
    • Intracutaneous Irritation Study
    • Skin Sensitization Study
    • Pyrogen Test
    • Acute Intravenous Systemic Toxicity Study
    • Acute Intraperitoneal Systemic Toxicity Study
    • Salmonella Reverse Mutation Test
    • In Vitro Mammalian Chromosomal Aberration Test
    • Rodent Micronucleus Test
    • Bone Implantation Study
    • Subchronic Intravenous Systemic Toxicity Study
    • Static and Dynamic axial Compress Bending Testing
    • Static Torsional Test

    The document states that "All the test results demonstrate that HC Spinal system meets the requirements of its pre-defined acceptance criteria and intended uses." Specifically, for performance, it notes compliance with ASTM F1717. The purpose of these tests was to demonstrate the safety and performance of the device and to establish substantial equivalence to the predicate device (Xia® 4.5 Spinal System) under 510(k) regulations. No clinical test data was used to support this decision.

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    K Number
    K110425
    Date Cleared
    2012-07-27

    (529 days)

    Product Code
    Regulation Number
    872.3640
    Panel
    Dental
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The HC-Bios Dental Implant System is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, and to restore the patient's chewing function.

    This may be accomplished by either a two-stage surgical procedure or a single surgical procedure. If a single surgical procedure is used, single or multiple implants may be inserted (type I, II or III bone) provided good initial stability (> 40 Ncm) is achieved. Not intended for immediate loading.

    Device Description

    The HC-Bios Dental Implant System is a device made of pure titanium metal and titanium alloy intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, and to restore the patient's chewing function. It consists of fixture, abutment, mount screw, cover screw, impression coping, analog, impression coping screw and plastic impression cap. Its materials, dimensions, and intended use are similar to devices currently marketed worldwide.

    AI/ML Overview

    Here's an analysis of the provided 510(k) summary for the HC-Bios Dental Implant System, focusing on acceptance criteria and the study proving adherence:

    The provided document describes a traditional 510(k) submission for a dental implant system. As such, the "study" proving the device meets acceptance criteria is primarily non-clinical testing demonstrating substantial equivalence to a predicate device. This is typical for Class II devices like dental implants. There is no mention of clinical studies involving human patients, AI components, or complex ground truth establishment for diagnostic performance.

    1. Table of Acceptance Criteria and Reported Device Performance

    Test CategoryAcceptance CriteriaReported Device Performance
    BiocompatibilityAdherence to recognized standards for biological evaluation of medical devices (ISO 10993 series)."A series of in vitro and in vivo preclinical physical, mechanical and biocompatibility tests were performed... The tests were conducted in accordance with ISO 10993-10, ISO 10993-10, ISO 10993-11, ISO 10993-12." (Note: ISO 10993-10 is listed twice, likely a typo.) These tests demonstrate the device "meets the requirements of its pre-defined acceptance criteria." The material is pure titanium and titanium alloy, which are well-established biocompatible materials for dental implants. The predicate uses titanium metal and titanium alloy; the proposed device uses Grade 4 titanium and AISI 316L Stainless Steel.
    Physical/MechanicalAdherence to recognized standards for mechanical testing of dental implants (ISO 14801, ASTM F 543, ASTM F 1980). Demonstrated performance comparable to the predicate device."A series of in vitro and in vivo preclinical physical, mechanical and biocompatibility tests were performed... The tests were conducted in accordance with ISO 14801, ASTM F 543, and ASTM F 1980." These tests demonstrate the device "meets the requirements of its pre-defined acceptance criteria." The document states, "The result of bench testing indicates that the new device is substantially equivalent to the predicate device."
    SterilizationAdherence to recognized standards for sterilization of medical devices (ISO 11137-1)."The tests were conducted in accordance with... ISO 11137-1." These tests demonstrate the device "meets the requirements of its pre-defined acceptance criteria."
    SubstantialSimilar intended use, design, technology/principles of operation, materials, and performance to the predicate device, with no new issues of safety or effectiveness raised by any differences.The document explicitly states the "HC-Bios Dental Implant System is substantially equivalent in intended use, design, technology/principles of operation, materials and performance to the Dentium Co., Ltd Implantium which is the subject of K041368." Bench testing results support substantial equivalence. The predicate and proposed devices share identical intended use, classification, and regulatory code. While materials differ (Grade 4 Ti & AISI 316L SS vs. Ti & Ti alloy), these are all standard biocompatible materials for implants, and this difference is implicitly covered by the biocompatibility and mechanical testing. Dimensions have slightly larger ranges for the proposed device, but this is also addressed by testing.
    Initial StabilityAchieve > 40 Ncm upon insertion for single surgical procedures (for Type I, II, or III bone).This is an explicit indication for use criterion. While no specific test result is provided for this exact metric, the overall bench testing, particularly mechanical tests (ISO 14801, ASTM F 543), supports the device's ability to achieve appropriate initial stability, as it is deemed substantially equivalent for its intended use.

    Note: For medical devices seeking 510(k) clearance, the primary "acceptance criterion" is generally demonstrating substantial equivalence to a legally marketed predicate device. The performance data presented here is to support that claim of equivalence, often by showing the proposed device meets relevant performance standards and has similar characteristics to the predicate.


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

    • Test Set Sample Size: Not explicitly stated as a number of devices or cases. The "test set" refers to the samples of the HC-Bios Dental Implant System that underwent non-clinical (in vitro and in vivo preclinical) testing. These are typically representative samples of the manufactured device. The common practice for such testing involves a sufficient number of samples to achieve statistical significance or meet the requirements of the specific test standard (e.g., a certain number of fatigue test samples).
    • Data Provenance: The tests were "in vitro and in vivo preclinical" and "bench testing." This refers to laboratory and possibly animal testing. The location of the testing laboratories is not specified, but the manufacturer is based in Taiwan. The data is entirely retrospective relative to the 510(k) submission, meaning the tests were completed before the submission. There is no indication of human patient data provenance.

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

    This information is not applicable in the context of this 510(k) submission.

    • No Human Experts for Ground Truth: Since this is non-clinical testing of a physical medical device (dental implant), there is no 'ground truth' established by a panel of human experts in the way one would for an AI diagnostic algorithm. The "truth" or "correctness" of the device's performance is determined by its adherence to established engineering, material, and biocompatibility standards (e.g., ISO, ASTM).
    • Qualifications: The tests would have been performed by engineers, materials scientists, and toxicologists familiar with the respective ISO/ASTM standards and Good Laboratory Practices (GLP), but they are not acting as "experts establishing ground truth" in a diagnostic sense.

    4. Adjudication Method for the Test Set

    This is not applicable for non-clinical device testing described in this 510(k). Adjudication methods like 2+1 or 3+1 refer to processes for resolving disagreements among multiple human readers when establishing ground truth, typically in imaging or clinical diagnostic studies. For physical device testing, the results are objectively measured against predefined standard criteria.


    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of Human Readers Improving with AI vs. Without AI Assistance

    This information is not applicable.

    • No AI Component: The HC-Bios Dental Implant System is a physical dental implant. There is no mention of any AI component, software, or diagnostic capabilities that would involve human readers or AI assistance.
    • No MRMC Study: Consequently, an MRMC comparative effectiveness study, which is typically performed for AI-powered diagnostic devices, was not performed.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    This information is not applicable. As stated above, there is no AI algorithm or software product in this submission. This is a physical medical device.


    7. The Type of Ground Truth Used

    For this device and submission type, the "ground truth" is defined by:

    • Established Industry Standards: ISO 10993 (biocompatibility), ISO 14801 (mechanical testing for dental implants), ASTM F 543, ASTM F 1980, and ISO 11137-1 (sterilization).
    • Predicate Device Performance: The performance characteristics and safety profile of the legally marketed Dentium Co., Ltd Implantium (K041368). The "ground truth" for substantial equivalence is that the proposed device performs comparably to this predicate given its intended use.
    • Material Properties: The established safety and performance characteristics of Grade 4 titanium and AISI 316L Stainless Steel in medical applications.

    8. The Sample Size for the Training Set

    This information is not applicable. There is no machine learning or AI component to this device, and therefore no "training set." The device is a physical implant, not a data-driven model.


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

    This information is not applicable for the same reasons as point 8.

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