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510(k) Data Aggregation

    K Number
    K223753
    Date Cleared
    2023-03-14

    (90 days)

    Product Code
    Regulation Number
    888.3060
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Cervical Plate System is intended for anterior interbody screw fixation from C2 to T1 and is indicated for use in the temporary stabilization of the anterior spine during the development of cervical spinal fusions in patients with: 1) degenerative disc disease (as defined by neck pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies); 2)trauma (including fractures); 3)tumors: 4)deformity(defined as kyphosis, lordosis,or scoliosis); 5)pseudoarthrosis; 6)failed previous fusions

    Device Description

    Cervical Plate System consist of anterior cervical spine plate II, anterior cervical spine plate IV and screws. The anterior cervical spine plate is fixed to the front of the cervical vertebrae by screws to play an auxiliary role in maintaining the stability of the surgical segment and preventing the fusion implant from coming out. Screws are available for fixed angle or variable angle implantation.

    Bone plates in Cervical Plate System are made of unalloyed titanium following ASTM F67 and titanium alloy following ASTM F1472 as well as ASTM F1295, and bone screws in Cervical Plate System are made of titanium alloy following ASTM F136.

    Cervical Plate System is provided as non-sterile. The implants are intended for single-use only, while the instruments are reusable.

    AI/ML Overview

    This document, K223753, is a 510(k) premarket notification for a Cervical Plate System. It seeks to demonstrate substantial equivalence to a legally marketed predicate device (K141632 ZEVO™ Anterior Cervical Plate System).

    The request asks for acceptance criteria and a study that proves the device meets these criteria. However, the provided text does not contain information about an AI/ML-based medical device, nor does it describe a study involving human-in-the-loop performance, expert consensus on images, or training/test sets for an algorithm.

    Instead, this submission details the regulatory approval process for a physical orthopedic implant used in spinal surgery. The "acceptance criteria" discussed are primarily related to biocompatibility and mechanical testing of the physical device to ensure its safety and efficacy, not performance metrics of an AI algorithm.

    Therefore, I cannot provide the requested information. The document explicitly states:

    • "No clinical performance data was provided to demonstrate substantially equivalence." (Section 5.8)
    • The non-clinical performance data focuses on biocompatibility testing (ISO 10993-1) and mechanical testing (ASTM F1717) for the physical implant (Static compression bending test, Static torsion test, Dynamic compression bending test).

    To explicitly answer your questions based only on the provided text, and acknowledging the mismatch with your request for AI/ML study details:

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

      • Acceptance Criteria (Implied from tests performed): The Cervical Plate System must demonstrate biocompatibility and mechanical performance (static compression bending, static torsion, dynamic compression bending) that is substantially equivalent to the predicate device, as per ASTM F1717 and ISO 10993-1.
      • Reported Device Performance: The document states these tests were "performed... to demonstrate substantially equivalent of safety and efficacy with the predicate device," but it does not provide numerical results or specific performance metrics from these tests. It only states that the information provided "demonstrates that proposed device is determined to be substantially equivalent (SE) to the predicate device." This implies the acceptance criteria were met, but the specific data is not in this summary.
    2. Sample sizes used for the test set and the data provenance: This is not applicable to this document as it does not describe an AI/ML study with test sets of data. The "test set" here refers to physical samples of the cervical plate subjected to mechanical and biocompatibility tests. No information on the number of physical samples tested is provided, nor is the "provenance" of such samples described in terms of geographical origin or retrospective/prospective collection.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: This is not applicable. Ground truth, in the context of an AI/ML study, would involve expert labeling of medical images or data. No such process is described for this physical device. The "ground truth" for a physical device is its material properties and mechanical behavior under stress.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: This is not applicable as there is no data labeling or consensus-building process for an AI/ML system.

    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 is not applicable to this submission. The device is a physical implant, not an AI assistance tool for human readers.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: This is not applicable. There is no algorithm described.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): For a physical device, "ground truth" refers to established material properties and biomechanical standards. The document refers to ASTM F1717 (Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model) and ISO 10993-1 (Biological evaluation of medical devices). These standards serve as the "ground truth" for evaluating the physical and biological characteristics of the device.

    8. The sample size for the training set: This is not applicable as there is no AI/ML model or training set.

    9. How the ground truth for the training set was established: This is not applicable as there is no AI/ML model or training set.

    In summary, the provided document is a 510(k) summary for a physical medical device (Cervical Plate System) and does not involve AI/ML technology or studies with expert reading of medical images.

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    K Number
    K201979
    Manufacturer
    Date Cleared
    2020-08-25

    (40 days)

    Product Code
    Regulation Number
    888.3060
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Cervical Plate System is intended for anterior screw fixation of the cervical spine (C2-C7) as an adjunct to fusion. These implants have been designed to provide stabilization for the treatment of the following indications: degenerative disc disease (defined as neck pain of discogenic origin with the degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e., fractures or dislocations), spinal stenosis, deformity (i.e., kyphosis, or scoliosis), tumor, pseudarthrosis or failed previous fusion.

    Device Description

    The Cervical Plate System is an anterior cervical plating system that consists of plates and selftapping screws. The implants are available in a variety of shapes to accommodate the anatomical condition of patients. The subject device components are manufactured from titanium alloy (Ti-6Al-4V ELI) per ASTM F136.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the Cervical Plate System, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Performance Test)Reported Device Performance
    Static compression bending per ASTM F1717"sufficient for its intended use"
    Static torsion per ASTM F1717"sufficient for its intended use"
    Dynamic compression bending per ASTM F1717"sufficient for its intended use"

    Note: The document states that the mechanical performance data leads to the conclusion that the device is "substantially equivalent" to the predicate device. However, it does not explicitly provide numerical acceptance criteria or specific numerical results for these tests. It only states that the device's strength is "sufficient" and comparable to predicate devices.

    2. Sample Size for Test Set and Data Provenance

    This information is not provided in the document. The studies mentioned are mechanical performance tests (in vitro), not clinical studies involving human patients or data. Therefore, concepts like country of origin for data or retrospective/prospective studies are not applicable here.

    3. Number of Experts and Qualifications for Ground Truth

    This information is not applicable as the evaluation relies on mechanical testing against ASTM standards, not expert review of clinical data.

    4. Adjudication Method for Test Set

    This information is not applicable as the evaluation relies on mechanical testing against ASTM standards, not expert review of clinical data.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    A multi-reader multi-case (MRMC) comparative effectiveness study was not done. The submission focuses on the mechanical substantial equivalence of a physical medical device (Cervical Plate System) through in vitro testing, not on evaluating the effectiveness of an AI algorithm or human reader performance.

    6. Standalone (Algorithm Only) Performance Study

    This information is not applicable. The device described is a physical implant (Cervical Plate System), not an algorithm or AI-driven system.

    7. Type of Ground Truth Used

    The "ground truth" for the device's performance is established by ASTM F1717 standards for static and dynamic mechanical properties of spinal intervertebral body fixation orthoses. The document states "The Cervical Plate System has been tested in the following test modes: - Static compression bending per ASTM F1717 . - Static torsion per ASTM F1717 ● - Dynamic compression bending per ASTM F1717".

    8. Sample Size for Training Set

    This information is not applicable. There is no mention of a "training set" as this is a mechanical device, not an AI or machine learning system that requires training data.

    9. How Ground Truth for Training Set Was Established

    This information is not applicable for the same reason as above; there is no training set mentioned or implied for this mechanical device.

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