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510(k) Data Aggregation

    K Number
    K251131
    Manufacturer
    Date Cleared
    2025-06-06

    (56 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Annex**®** 2 Adjacent Level System

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    When used with pedicle screw fixation systems, the Annex® 2 Adjacent Level System is 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 disc disease; spondylolisthesis; fracture; dislocation; scoliosis; kyphosis; spinal tumor; and failed previous fusion (pseudarthrosis).

    The Annex® 2 Adjacent Level System can be linked to 4.75 mm, 5.5 mm, and/or 6.0 mm diameter rods of the following systems: CapSure®, Sniper® or Salvo® Spine Systems.

    Device Description

    The Annex® 2 Adjacent Level System consists of a selection of non-sterile, single-use locking screws, adjacent level devices, and connectors for attachment to an existing pedicle spinal fixation construct to extend a rigid spinal construct. The Annex® 2 Adjacent Level System components are provided in a variety of sizes and shapes to accommodate variations in anatomy and spacing between existing screw and rod hardware. The implant components of this system are manufactured from titanium (ASTM F67)), titanium alloy (Ti-6Al-4V ELI (ASTM F136)), and cobalt-chromium (CoCr (ASTM F1537)).

    AI/ML Overview

    The provided FDA 510(k) clearance letter pertains to a medical device, the Annex® 2 Adjacent Level System, which is a physical implant, not an AI/ML-driven software device. Therefore, the information requested regarding acceptance criteria and study design for AI/ML performance metrics (such as test set size, data provenance, expert qualifications, adjudication methods, MRMC studies, standalone performance, and training set details) is not applicable to this document.

    The document discusses non-clinical testing to support substantial equivalence for a physical medical implant. Here's a summary of the relevant information from the provided document:

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

    The document mentions that non-clinical testing was performed, but it does not explicitly state specific pass/fail acceptance criteria or quantitative performance results in the provided text. It generally concludes that the device is "substantially equivalent" based on these tests.

    Acceptance Criteria (Not Explicitly Stated)Reported Device Performance (Summary)
    Mechanical performance (e.g., strength, durability under axial compression bending, torsion) comparable to predicate devices.Non-clinical testing (Static axial compression bending, static torsion testing, and dynamic axial compression bending testing per ASTM F1717) found "substantial equivalence" to legally marketed predicate devices.

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

    • Sample size: Not specified in the document.
    • Data provenance: Not applicable in the context of clinical data for a physical implant. The testing described is non-clinical mechanical testing.

    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 involved non-clinical mechanical testing of a physical device, not expert interpretation of AI/ML output.

    4. Adjudication method for the test set:

    Not applicable as the study involved non-clinical mechanical testing of a physical device, not subjective interpretation 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, as this is a physical medical device, not an AI-assisted diagnostic tool.

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

    Not applicable, as this is a physical medical device, not an AI algorithm.

    7. The type of ground truth used:

    For mechanical testing, the "ground truth" would be established by standardized testing methods and material properties, rather than expert consensus, pathology, or outcomes data. The document states testing was performed "per ASTM F1717," indicating adherence to a recognized standard for spinal implant testing.

    8. The sample size for the training set:

    Not applicable, as this is a physical medical device, not an AI/ML system requiring a training set.

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

    Not applicable, as this is a physical medical device, not an AI/ML system.


    In summary, the provided document is a 510(k) clearance letter for a physical orthopedic implant system. The study mentioned (non-clinical testing per ASTM F1717) focuses on establishing mechanical and material equivalence to predicate devices, not on AI/ML performance metrics.

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