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510(k) Data Aggregation
(81 days)
BACFIX SPINAL FIXATION SYSTEM
The SCI BacFix® Ti Spinal Fixation System consists of a combination of components which include rods, hooks, locking wedges, screws, transverse connectors, cable-screws, cables and spinous process grommets which are indicated to provide temporary stability of the thoracic, thoracolumbar, or lumbar spine (T1 to S1).
When intended for pedicle screw fixation, implants are 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 or sacral spine: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor and failed previous fusion (pseudarthrosis). Levels of pedicle screw attachment for these indications range to T1 to the sacrum.
As a pedicle screw system, the BacFix® Spinal Fixation System is also intended for patients having Grade 3 or Grade 4 spondylolisthesis at LS-S1, when utilizing autologous bone graft, when affixed to the posterior when deling and intended to be removed after solid fusion is established. Levels of pedicle screw fixation for this indication are from L3 to the sacrum.
When intended for non-pedicle, posterior screw fixation of the non-cervical spine, the indications are:
- Idiopathic scoliosis.
- Neuromuscular scoliosis/kyphoscoliosis with associated paralysis or spasticity.
- Scoliosis with deficient posterior elements such as that resulting from laminectomy or myelomeningocele.
- Spinal fractures (acute reduction or late deformity).
- Degenerative disc disease (back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies).
- Neoplastic disease.
- Spondylolisthesis.
- Spinal Stenosis.
- Failed previous fusion.
The cable-screws, cables and spinous process grommets are indicated for:
- Defect of pars lateralis.
- Spondylolisthesis.
Cables and spinous processes grommets may be used for interspinous wiring if additional stability is needed.
The Bach IT Spinal Fixation System is intended to or also with ASTM F136. The BacFix Spinal System is manufactured from thamall andy, which vehip.comectors and other ancillary components. The FTRaton System moudes secews, 1003, noored for market under K973687, and supplemented through II (calif Bach IX 11 Spillar Fixation System was cleared ink transverse connector), K003351 (addition of additional JTUK Submissions: Troughts (addition of end-to-end and side-by-side connectors).
The provided document describes the BacFix Spinal Fixation System and its substantial equivalence to a predicate device, the Isola Spinal System, rather than presenting a study to prove acceptance criteria for a novel device through clinical trials or performance metrics against specific targets. This 510(k) submission relies on nonclinical (biomechanical) testing to demonstrate equivalence.
Here's a breakdown based on the information provided:
1. Table of Acceptance Criteria and Reported Device Performance
Instead of traditional acceptance criteria with quantitative performance metrics, this submission uses the concept of "substantial equivalence" to a predicate device. The primary "acceptance criterion" is that the BacFix system's biomechanical properties fall within the established range of the predicate device.
Acceptance Criterion (via Substantial Equivalence to Isola Spinal System) | Reported Device Performance (BacFix Spinal Fixation System) |
---|---|
Indications for Use: Same as predicate device (Isola Spinal System). | Same as predicate, encompassing temporary stability of the thoracic, thoracolumbar, or lumbar spine (T1 to S1), pedicle screw fixation for various conditions (T1 to sacrum), Grade 3 or 4 spondylolisthesis at L5-S1, and non-pedicle posterior screw fixation for non-cervical spine. Special indications for cable-screws, cables, and spinous process grommets. |
Materials: Biocompatible, similar to predicate. | Titanium 6Al-4V. Predicate uses Stainless steel or titanium. (Deemed equivalent, as both are biocompatible and commonly used in spinal implants). |
Components: Similar screws, rods, hooks, transverse connectors. | Screws, rods, hooks, transverse connectors. Predicate has "Same." |
Product Labeling: Includes all necessary warnings. | Instructions for use and box labeling including all the necessary warning statements. Predicate has "Same." |
Packaging/Sterilization: Non-sterile, single use only. | Non-sterile, single use only. Predicate has "Same." |
Biomechanical Test Results: Stiffness range, per ASTM 1717-96, must be within the range of the Isola Spinal System. | Stiffness range, per ASTM 1717-96, within the range of the Isola Spinal System. |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: Not explicitly stated in terms of number of devices or constructs. The document mentions "Mechanical testing was conducted on the stiffest and most flexible data collected for BacFix data." This implies a limited set of configurations or specimens were tested to represent the range of the device. The data provenance is not specified, but it would have been generated in a controlled laboratory setting (nonclinical).
- Data Provenance: Nonclinical, laboratory-generated biomechanical test data designed to conform to ASTM F1717-96 (Standard Test Methods for Spinal Implant Constructs in a Corpectomy Model).
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
Not applicable. This is a nonclinical bench test, not a study involving expert assessment of medical images or patient outcomes. The "ground truth" here is the physical performance of the device under mechanical load, measured against established engineering standards (ASTM F1717-96) and compared to a predicate device's known performance.
4. Adjudication Method for the Test Set
Not applicable. This is a nonclinical bench test. No adjudication by human observers is 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 a 510(k) submission for a spinal fixation system, not an AI/imaging device. No MRMC study was performed or described.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Not applicable. This is a mechanical device, not an algorithm.
7. The Type of Ground Truth Used
The "ground truth" for this submission is the biomechanical performance data (stiffness range) of the BacFix system as measured according to ASTM F1717-96, and then compared to the known biomechanical performance data of the Isola Spinal System, also measured against the same standard. Essentially, direct physical measurement against a standardized test method.
8. The Sample Size for the Training Set
Not applicable. This is a mechanical device that does not use a "training set" in the context of machine learning.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no "training set" for this type of device submission.
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(35 days)
MODIFICATION TO SPINAL CONCEPTS BACFIX SPINAL FIXATION SYSTEM
The Spinal Concepts, Inc. BacFix™ Spinal Fixation System consists of a combination of components which include rods, hooks, locking wedges, screws and transverse connectors which are indicated to provide temporary stability of the thoracic, thoracolumbar or lumbar spine (T)-SI).
When intended for pedicle screw fixation, implants are 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 spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor and failed previous fusion (pseudarthrosis). Levels of pedicle screw attachment for these indications range from T1 to the sacrum.
In addition, when intended for pedicle screw fixation, implants are intended for treatment of severe spondylolisthesis (grades 3 and 4) of the vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine with removal of implants after the attainment of solid fusion. The levels of screw fixation for these indications range from L3 to the sacrum.
When intended for non-pedicle, posterior screw fixation of the noncervical spine, the indications are:
- Idiopathic scoliosis.
- Neuromuscular scoliosis/kyphoscoliosis with associated paralysis or spacticity.
- Scoliosis with deficient posterior elements such as that resulting from laminectomy or myelomeningocele.
- Spinal fractures (acute reduction or late deformity).
- Degenerative disc disease (back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies).
- Neoplastic disease.
- Spondylolisthesis.
- Spinal stenosis.
- Failed previous fusion.
The BacFix™ Spinal Fixation System consists of longitudinal members (spinal rods), in a variety of diameters (1/4" and 3/16") and lengths; spinal anchor components, hooks and screws, of various sizes (6.0-7.5mm diameter screws) and types; locking connectors (wedge and nut) sized to fit the spinal rods; and a transverse connector assembly (link), also in various lengths. Hooks and screws may be placed at any position along the spinal rods and are secured with a three point shear clamp (wedge and nut). The open face of the wedge may be snapped over the spinal rod. Thus the component and wedge may be preassembled outside the wound, eliminating the need to attach the nut within the surgical opening and the need to pre-plan the position of each eyebolt on the spinal rod. Furthermore, an anchor component may be added to (or removed from) the construct at any time during the procedure.
The provided document describes the BacFix™ Spinal Fixation System (K983258), a medical device. The "study" that proves the device meets acceptance criteria is a mechanical testing comparison study rather than a clinical trial involving human subjects. This is a common approach for Class II medical devices seeking 510(k) clearance, where substantial equivalence to a legally marketed predicate device is the primary pathway.
Here's a breakdown of the requested information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Withstand clinical loading | "demonstrated the BacFix™ to be substantially equivalent to the Zimmer Modulock Posterior Spinal System and the Sofamor Danek TSRH Spinal System and able to withstand clinical loading" |
Maintain mechanical integrity | "demonstrated the BacFix™ to be substantially equivalent to the Zimmer Modulock Posterior Spinal System and the Sofamor Danek TSRH Spinal System and able to ... maintain mechanical integrity." |
Substantial equivalence to predicate devices (Zimmer Modulock, Sofamor Danek TSRH) in material, design, and function | The entire "Substantial Equivalence" section (III) details the claimed equivalence in materials (316L Stainless Steel & 22-13-5 Stainless Steel), design (longitudinal members, hooks, screws, locking connectors, transverse connector assembly), and function (indications for use, as confirmed by mechanical testing). |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The document does not specify the exact number of test samples (e.e. rods, screws, hooks) used for the static and fatigue mechanical testing.
- Data Provenance: Not explicitly stated, but the testing would have been conducted in a laboratory setting, likely in the US, as the company is based in Austin, Texas. It is a prospective test in the sense that the device was manufactured specifically for these tests. It is not related to patient data.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- This question is not applicable in the traditional sense for this type of mechanical testing. The "ground truth" for mechanical testing is established by engineering standards and comparative data with predicate devices, not by expert consensus on clinical cases. The comparison was to published data of predicate devices.
4. Adjudication Method for the Test Set
- Not applicable. Mechanical testing data is evaluated against pre-defined engineering standards and comparative data, not through an adjudication process by human experts.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, an MRMC study was not done. This is a mechanical device, and its approval is based on substantial equivalence to predicate devices through material and mechanical performance, not through a comparative effectiveness study involving human readers or clinical outcomes in the way AI/radiology devices might.
6. Standalone Performance Study
- Yes, a standalone study was done, but it's mechanical. The "Mechanical Testing" section (VII) describes static and fatigue testing performed solely on the BacFix™ System. The results of this standalone testing were then compared to published data of "various other hook, rod and screw spinal fixation systems." This is a standalone performance of the device's mechanical properties, not a standalone algorithm performance.
7. Type of Ground Truth Used
- The "ground truth" for this device's performance evaluation is based on:
- Engineering Standards: Implied standards for static and fatigue strength for spinal fixation systems.
- Predicate Device Performance Data: Published mechanical testing data from the Zimmer Modulock Posterior Spinal System and the Sofamor Danek TSRH Spinal System.
8. Sample Size for the Training Set
- Not applicable. This device is a physical medical implant, not an AI/ML algorithm that requires a "training set" of data.
9. How the Ground Truth for the Training Set Was Established
- Not applicable. As above, there is no "training set" for a physical medical device.
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(142 days)
BACFIX SPINAL FIXATION SYSTEM
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