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510(k) Data Aggregation
(119 days)
K7 LLC
The Aversion Pedicle Screw System is intended for posterior, noncervical (T1-S1) pedicle fixation to provide immobilization and stabilization in skeletally mature patients as an adjunct to fusion for the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra; degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, spinal stenosis, scoliosis, kyphosis, lordosis, spinal tumor, pseudarthrosis and failed previous fusion
The Aversion Pedicle Screw System consists of straight and curved rods, polyaxial pedicle screws and crosslink connectors. These are available in a variety of sizes to accommodate differing patient anatomy.
This is a 510(k) premarket notification for a medical device called the "Aversion Pedicle Screw System." It is not an AI/ML device, therefore the requested information (acceptance criteria, study details, sample sizes, ground truth, expert qualifications, adjudication, MRMC, or standalone performance) related to AI/ML device testing is not applicable.
The document describes a traditional medical device, a pedicle screw system, and focuses on demonstrating its substantial equivalence to a legally marketed predicate device based on:
- Technological characteristics: Basic design (rod-based fixation), material (titanium alloy), anatomic location (non-cervical spine), and sizes.
- Performance Data: Mechanical testing (static compression bending and torsion, dynamic compression bending, and pullout testing) performed according to ASTM F1717 and ASTM F543 standards. The results demonstrated substantial equivalence in performance to the predicate devices.
Therefore, I cannot fulfill the request for information on acceptance criteria, study details, sample sizes, ground truth, expert qualifications, adjudication, MRMC, or standalone performance as these concepts are specifically relevant to AI/ML device evaluations, which this document does not describe.
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(70 days)
K7 LLC
The K7 Lumbar Spacers are indicated for intervertebral body fusion of the lumbar spine, from L2 to S1, in skeletally mature patients who have had six months of non-operative treatment. The device is intended for use at either one level or two contiguous levels for the treatment of degenerative disc disease (DDD) with up to Grade I spondylolisthesis or retrolisthesis. DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. The device is intended for use with supplemental fixation and with autograft to facilitate fusion.
The K7 Lumbar Spacers are a collection of radiolucent interbody devices having variously shaped cross-sections. The superior and inferior surfaces are open with parallel serrations to facilitate implant stability. The implants are available in an assortment of height, length, width and anteroposterior angulation combinations to accommodate a variety of anatomic requirements.
The provided text describes the K7 Lumbar Spacers, a medical device for intervertebral body fusion. The study presented focuses on demonstrating substantial equivalence to predicate devices through mechanical testing, rather than a clinical study evaluating the device's performance in a human population.
Therefore, many of the requested categories related to clinical performance metrics, ground truth establishment, expert involvement, and reader studies are not applicable or cannot be extracted from this document, as the FDA 510(k) submission for this device type typically relies on demonstrating engineering and material equivalence for clearance.
Here's a breakdown of the information that can be extracted, and where the requested information is not applicable:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (from predicate devices / standards) | Reported Device Performance (K7 Lumbar Spacers) |
---|---|
Mechanical Testing: |
- Static Compression (according to ASTM F2077)
- Dynamic Compression (according to ASTM F2077) | Performance shown to be substantially equivalent to predicate devices. |
| Subsidence Properties: - Evaluated according to ASTM F2267 | Performance shown to be substantially equivalent to predicate devices. |
| Technological Characteristics: - Intended Use
- Basic Design (hollow column)
- Material (PEEK polymer and tantalum)
- Sizes (widths, lengths, heights within predicate range) | Same as predicate devices. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: Not explicitly stated as a "test set" in the context of clinical data. The mechanical testing was likely performed on a representative sample of K7 Lumbar Spacers of the "worst case" configuration. The specific number of units tested for static, dynamic compression, and subsidence is not provided.
- Data Provenance: The data is from mechanical testing of the device itself (K7 Lumbar Spacers) in a laboratory setting, not from human subjects. Therefore, country of origin or retrospective/prospective clinical data is not applicable.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
- This is not applicable. The "ground truth" for this device's regulatory clearance is established by engineering standards (ASTM F2077, ASTM F2267) and comparison to predicate device characteristics, not by expert clinical consensus on a "test set" of patient data.
4. Adjudication Method for the Test Set
- This is not applicable, as there was no clinical "test set" involving human interpretation or adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, an MRMC comparative effectiveness study was not done. This device is a spinal implant, and its regulatory clearance here is based on mechanical performance and material equivalence, not on the interpretative performance of a diagnostic algorithm or image analysis by human readers.
6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study
- No, a standalone study in the context of AI algorithm performance was not done. This device is a physical implant, not an AI algorithm.
7. Type of Ground Truth Used
- For the mechanical performance, the "ground truth" is defined by engineering standards (ASTM F2077 for compression, ASTM F2267 for subsidence) and the established performance/characteristics of legally marketed predicate devices. The goal was to demonstrate that the K7 Lumbar Spacers met or were equivalent to these benchmarks.
8. Sample Size for the Training Set
- This is not applicable. There is no "training set" in the context of machine learning or AI as this is a physical medical device.
9. How the Ground Truth for the Training Set Was Established
- This is not applicable. See point 8.
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(63 days)
K7 LLC
When used as a cervical intervertebral fusion device, the K7C™ spacers are indicated for use at one level in the cervical spine, from C2-T1, in skeletally mature patients who have had six weeks of non-operative treatment for the treatment of degenerative disc disease (DDD) with up to Grade 1 spondylolisthesis. DDD is defined as neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. The device is intended for use with autogenous bone graft and with supplemental fixation systems cleared for use in the cervical spine.
The K7C™ Spacer is a collection of radiolucent interbody devices having a keystone-shaped cross-section. The superior and inferior surfaces are open with parallel serrations to facilitate implant stability. The implants are available in an assortment of height, length, width and anteroposterior angulation combinations to accommodate a variety of anatomic requirements.
The provided text describes a medical device, the K7C™ Spacer, and its mechanical testing for a 510(k) submission. However, it does not contain the specific information requested about acceptance criteria for device performance in the format of a table, nor does it detail a clinical study with human subjects, ground truth establishment, or expert involvement as outlined in the request.
Therefore, many of the requested elements cannot be extracted directly from the provided text.
Here's an analysis based on the available information:
1. Table of acceptance criteria and the reported device performance:
The document states: "Mechanical testing of the worst case K7C™ spacer was performed according to ASTM F2077 and included static and dynamic compression and static and dynamic torsion. The subsidence properties were evaluated according to ASTM F2267. The mechanical test results demonstrate that the K7C™ Spacers perform as well as or better than the predicate devices."
This indicates that the acceptance criteria were likely defined by the performance of the predicate devices in these specific ASTM standards (ASTM F2077 and ASTM F2267). The reported device performance is stated as "perform as well as or better than the predicate devices."
Acceptance Criteria (Inferred) | Reported Device Performance |
---|---|
Performance equivalent to or better than predicate devices in: | Performed as well as or better than predicate devices in: |
- Static compression (ASTM F2077) | - Static compression (ASTM F2077) |
- Dynamic compression (ASTM F2077) | - Dynamic compression (ASTM F2077) |
- Static torsion (ASTM F2077) | - Static torsion (ASTM F2077) |
- Dynamic torsion (ASTM F2077) | - Dynamic torsion (ASTM F2077) |
- Subsidence properties (ASTM F2267) | - Subsidence properties (ASTM F2267) |
2. Sample sized used for the test set and the data provenance:
The document mentions "mechanical testing of the worst case K7C™ spacer." This suggests a limited sample size, likely a few units chosen to represent the most challenging design. It does not provide an exact number. The data provenance is from mechanical testing, not human subjects, and is likely conducted in a laboratory setting (prospective testing of manufactured devices). No country of origin for this specific testing data is mentioned, but the sponsor is in Henderson, NV, USA.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
This information is not applicable as the study described is mechanical testing of a medical device, not a study involving human diagnosis or interpretation where expert ground truth would be established.
4. Adjudication method for the test set:
This information is not applicable for 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:
This information is not applicable. The document describes mechanical testing of an intervertebral fusion device, not an AI-powered diagnostic tool requiring MRMC studies.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
This information is not applicable. The device is a physical implant, not an algorithm.
7. The type of ground truth used:
For mechanical testing, the "ground truth" would be the objective physical measurements obtained according to the specified ASTM standards. These standards themselves establish the methodology for determining the performance characteristics.
8. The sample size for the training set:
This information is not applicable. There is no "training set" as this is mechanical testing of a physical device, not a machine learning model.
9. How the ground truth for the training set was established:
This information is not applicable as there is no training set mentioned or implied.
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