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510(k) Data Aggregation

    K Number
    K993503
    Date Cleared
    2000-04-14

    (182 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    INTERNATIONAL ADVANCED MEDICAL ENTERPRISES, INC.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use
    1. Spondylolisthesis Spinal Fixation Device System, 87MNH the intended use and indications for use are:
      The HAIDER-UCR Spinal System is a pedicle screw system indicated for the . treatment of severe spondylolisthesis (Grades 3 and 4) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine (L3 to sacrum) with removal of the implants after the attainment of a solid fusion.
    2. Pedicle Screw Spinal System, (Class II uses) 87MNI the intended use and indications for use are:
      . The HAIDER-UCR Spinal System is a pedicle screw 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:
    • degenerative with objective evidence of neurological ● spondylolisthesis impairment,
    • . fracture,
    • dislocation, ●
    • scoliosis, .
    • kyphosis.
    • spinal tumor, and ●
    • failed previous fusion pseudarthrosis). .
    Device Description

    The HAIDER-UCR Spinal System is a pedicle screw system. The system components include Titanium Pedicle screws, Pedicle Screw Components (Set Screw, Washer, Cap, Housing), Screw Sub-Assembly, Crosslink (Cross Link Nut, Cross Link Hook, Cross-link Bar), 5.5 mm Titanium Rods, and Accessories (Hex 3mm Screw Driver, Hex 4mm Screw Driver). The system is made from titanium alloy (6Al, 4V, Ti).

    AI/ML Overview

    The provided text describes a medical device, the HAIDER-UCR Spinal System, and its regulatory submission (510(k)) to the FDA. It details device characteristics, indications for use, materials, and testing summarized in comparison to a predicate device.

    However, the document is a 510(k) Pre-market Notification, which is a submission to the FDA to demonstrate that a device is substantially equivalent to a legally marketed predicate device. This type of submission primarily focuses on comparing the new device to an existing one for safety and effectiveness, rather than providing a detailed study proving the new device meets specific, quantitative acceptance criteria through clinical trials or extensive standalone performance studies in the way you might expect for a novel AI/software medical device.

    Therefore, many of the requested categories (e.g., sample size for test set, number of experts, adjudication method, AI efficacy studies, ground truth establishment) are not applicable or not present in this type of regulatory document for this specific device. The HAIDER-UCR Spinal System is a mechanical implant, and its performance is evaluated through material specifications, mechanical testing, and comparison to an established predicate.

    Here's an attempt to answer based on the provided text, indicating where information is not available or not relevant to this type of device submission:


    Acceptance Criteria and Device Performance Study (HAIDER-UCR Spinal System)

    The HAIDER-UCR Spinal System is a pedicle screw spinal system. Its acceptance criteria are primarily based on demonstrating substantial equivalence to a legally marketed predicate device (Synergy™ Spinal System, K974749) and compliance with relevant material and mechanical testing standards.

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for this device are largely defined by demonstrating equivalence to the predicate device and meeting specified engineering standards. The "reported device performance" in this context refers to the results of static and fatigue mechanical testing.

    Acceptance Criteria CategorySpecific CriteriaReported Device Performance
    Mechanical TestingStatic Testing: Compliance with ASTM F-1717-96 "Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model (Static and Fatigue)". Specifically, performance in compression bending, tension bending, and torsion of a typical system configuration. (Implied acceptance: performance equal to or better than predicate, or meeting established safety limits for such devices).

    Fatigue Testing: Compliance with ASTM F-1717-96. Establishment of an S/N (stress-number of cycles) curve with run-out points. (Implied acceptance: ability to withstand a specified number of load cycles without failure, equivalent to or better than predicate, or meeting established safety limits). | Static Testing: "Static tests of compression bending, tension bending and torsion of a typical system configuration indicated design performance was met. All samples were tested according to ASTM F-1717-96, the pedicle screw spinal system guideline."

    Fatigue Testing: "Samples subjected to cyclic fatigue testing also performed according to expectations. Seven constructs were tested and an S/N curve established. At least two run out points exceeded 5,000,000 load cycles." |
    | Materials | Compliance with quality and composition standards for Titanium alloy or 6Al, 4V, Ti titanium alloy. (Implied acceptance: meeting ISO or ASTM material specifications, and being the "SAME" material as the predicate). | "The system is made from a well known metallic alloy commonly known as titanium alloy or 6Al, 4V, Ti titanium alloy. This material meets or exceeds the quality and composition standards listed in the table below [table not legible for specific values, but indicates compliance]."

    Comparison Table: "Materials: Titanium alloy" and "Synergy™ Spinal System: SAME" (indicating equivalence). |
    | Indications for Use | Equivalence in indications for use to the predicate device. | The device "has been determined... substantially equivalent (for the indications for use stated in the enclosure) to devices marketed in interstate commerce prior to May 28, 1976...".

    Comparison Table: "Indications for Use: SAME" as Synergy™ Spinal System. |
    | Sterility | Supplied "NON-STERILE" with a recommended sterilization process (high-temperature steam) that will achieve a Sterility Assurance Level (SAL) of at least 10⁻⁶. | "The HAIDER-UCR Spinal System is supplied 'NON-STERILE' and must be sterilized prior to use. The recommended sterilization process is high temperature sterilization. The recommended sterilization cycle will produce a Sterility Assurance Level (SAL) of at least 10⁶. The validated cycle is: Method: Steam Cycle: Gravity Temperature: 270°F (125°C) Exposure Time: 15 minutes."

    Comparison Table: "Sterile: Supplied Non-sterile Autoclave processed by end user" and "Synergy™ Spinal System: SAME". |
    | Design / Components | Equivalence in design (Rod, sacral screw, pedicle screw & cross-link system) and sizes (rods, pedicular screws) to the predicate device. | Comparison Table: "Design: Rod, sacral screw, pedicle screw & cross link system" and "Synergy™ Spinal System: SAME".

    "Sizes: Rods: 5.5mm dia. X 40-305mm length Pedicular screws 7.0mm 35mm, 40mm, 45mm" and "Synergy™ Spinal System: EQUIVALENT". |
    | Regulatory Compliance | Compliance with general controls and special controls (material standards, mechanical testing standard, biocompatibility standard, specified labeling requirements) for pedicle screw spinal systems. | The FDA's 510(k) clearance indicates compliance: "You may, therefore, market the device, subject to the general control provisions of the Act... If your device is classified... into... class II (Special Controls)... it may be subject to such additional controls." The document lists special controls that apply and states IAME, INC. meets appropriate general controls. |

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

    • Sample size for test set:
      • For mechanical testing (ASTM F-1717-96): "Seven constructs were tested" for cyclic fatigue. The number of samples for static tests (compression bending, tension bending, torsion) is not explicitly stated, but it mentions "All samples were tested." In the context of ASTM F1717, typically a minimum of 6 samples per test condition are recommended.
    • Data provenance: The data is generated from in vitro mechanical testing performed by the manufacturer, INTERNATIONAL ADVANCED MEDICAL ENTERPRISES, INC. The country of origin for the data is implicitly the USA, where the company and the FDA are located. The testing is prospective in the sense that it was conducted specifically to support this regulatory submission, rather than being collected retrospectively from a pre-existing dataset.

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

    • Not Applicable. This is a mechanical implant device. The "ground truth" for its performance is established through adherence to engineering standards (ASTM F-1717-96) measuring physical properties, not by expert interpretation of clinical data or images.

    4. Adjudication method for the test set

    • Not Applicable. As per point 3, there is no expert interpretation or "ground truth" in the sense of clinical assessment requiring adjudication. The compliance is assessed by comparing measured mechanical properties against standard requirements.

    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 medical device. No human-in-the-loop studies or AI assistance are relevant.

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

    • Not Applicable. This is not an AI/software medical device.

    7. The type of ground truth used

    • Engineering Standards and Predicate Device Equivalence: The "ground truth" is defined by the requirements of recognized engineering standards (e.g., ASTM F-1717-96) for mechanical performance and the established performance and safety profile of the legally marketed predicate device (Synergy™ Spinal System). For materials, it's compliance with material composition standards.

    8. The sample size for the training set

    • Not Applicable. This is not an AI/software medical device for which a "training set" in the machine learning sense would be used. The design and manufacturing processes are informed by established engineering principles and prior knowledge from the predicate device and similar implants.

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

    • Not Applicable. As per point 8, there is no "training set" in this context. The "truth" for developing such a device relies on decades of biomedical engineering research, material science, surgical experience, and regulatory guidance for spinal implants.
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