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510(k) Data Aggregation

    K Number
    K120491
    Date Cleared
    2012-05-09

    (82 days)

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

    DSS STABILIZATION SYSTEM-RIGID

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

    The DSS™ Stabilization System - Rigid is intended for noncervical pedicle fixation from the T4 to S1 vertebrae in skeletally mature patients to help provide immobilization and stabilization of spinal segments as an adjunct to fusion for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, kyphosis, and/or lordosis); tumor; pseudarthrosis; and failed previous fusion. The DSSTM Stabilization System - Rigid is intended to be used with autograft and/or allograft.

    Note: The Rigid Couplers are for single-level use only. The traditional straight rods are for single- and multi-level use.

    The DSSTM Stabilization System - Slotted is intended to provide immobilization and stabilization of spinal segments 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, kyphosis, and failed previous fusion (pseudarthrosis).

    In addition, the DSS™ Stabilization System - Slotted is indicated for use in patients:

    • Who are receiving fusions with autogenous graft only;
    • Who are having the device fixed or attached to the lumbar or sacral spine;
    • Who are having the device removed after the development of a solid fusion mass.

    Note: The Rigid Coupler and Slotted Coupler are not intended to be used together.

    Device Description

    The DSSTM Stabilization System is comprised of a variety of pedicle screw sizes, couplers, and straight rods that act as longitudinal components that are uniquely fitted for each individual case. The pedicle screws, couplers, and straight rods are manufactured from medical grade titanium alloy (Ti6Al4V).

    The purpose of this 510(k) is to add multi-level use for the traditional straight rod components of the DSSTM Stabilization System - Rigid.

    AI/ML Overview

    The provided text is a 510(k) Summary for the DSS™ Stabilization System - Rigid. This document describes a medical device and its substantial equivalence to previously cleared devices. It does not contain information about a study involving human readers or AI assistance. The "study" described is a performance test to demonstrate mechanical equivalence, not clinical performance.

    Here's an analysis based on the information provided and what is typically found in a 510(k) for devices like this:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Test Standard)Reported Device Performance (Reference to Predicate)
    Static Compression Bending (ASTM F1717)Substantially equivalent to predicate devices (K042962, K080241, K090099, K090408, K101083, and K13625)
    Static Torsion (ASTM F1717)Substantially equivalent to predicate devices (K042962, K080241, K090099, K090408, K101083, and K13625)
    Dynamic Compression Bending (ASTM F1717)Substantially equivalent to predicate devices (K042962, K080241, K090099, K090408, K101083, and K13625)

    Explanation:
    For this type of device (spinal fixation system), the primary "acceptance criteria" and "device performance" in a 510(k) submission are typically based on mechanical testing per recognized standards (like ASTM F1717) to prove that the new device is functionally equivalent to existing cleared predicate devices. The document explicitly states that "Previous performance testing per ASTM F1717... and comparison to the predicates the DSS™ Stabilization System - Rigid is substantially equivalent to predicate devices." This means the performance of the new device met or exceeded the performance of the predicate devices in these mechanical tests, thus demonstrating substantial equivalence. The predicate devices themselves would have already established their safety and effectiveness through similar mechanical testing and potentially clinical use.

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size: The document does not specify the exact sample size for the mechanical tests. ASTM F1717 generally specifies the number of samples required for each test. For medical device mechanical testing, these are typically small numbers of physical device units (e.g., n=5, n=6, n=10 per test condition) rather than human subjects or data sets.
    • Data Provenance: Not applicable in the context of this 510(k). The "data" comes from physical mechanical testing of the device components, not from patient data, and is prospective in the sense that the tests were performed specifically for this submission.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    • This question is not applicable as the "test set" here refers to mechanical performance testing of a physical device, not an AI algorithm evaluated by human experts. The "ground truth" is based on the physical properties and mechanical behavior of the device components under various loads, as measured by standard laboratory equipment and procedures, not expert consensus.

    4. Adjudication Method for the Test Set

    • This question is not applicable for the same reasons as (3). Mechanical test results are typically objective measurements, not subject to individual expert 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

    • No, an MRMC comparative effectiveness study was not done. This document pertains to a physical medical device (spinal stabilization system), not an AI algorithm. Therefore, there is no discussion of human readers, AI assistance, or effect size related to AI improvement.

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

    • No, a standalone algorithm performance study was not done. This document is for a physical medical device, not an AI algorithm.

    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

    • The "ground truth" for the device's performance is established by objective measurements from standardized mechanical tests (per ASTM F1717). This involves measuring properties like displacement, load at failure, and fatigue cycles. The "truth" is the physical behavior of the material and design under controlled conditions, not a clinical outcome or expert interpretation.

    8. The Sample Size for the Training Set

    • Not applicable. There is no "training set" as this is a physical medical device, not a machine learning model.

    9. How the Ground Truth for the Training Set Was Established

    • Not applicable. There is no "training set" or corresponding ground truth establishment for a physical device.
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    K Number
    K113625
    Date Cleared
    2012-01-10

    (33 days)

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

    DSS STABILIZATION SYSTEM

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

    DSSTM Stabilization System - Rigid

    The DSSTM Stabilization System - Rigid is intended as a single-level system for noncervical pedicle fixation from the T4 to S1 vertebrae in skeletally mature patients to help provide immobilization and stabilization of spinal segments as an adjunct to fusion for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, and/or lordosis); tumor; pseudarthrosis; and failed previous fusion. The DSS™ Stabilization System - Rigid is intended to be used with autograft and/or allograft.

    DSSTM Stabilization System - Slotted

    The DSSTM Stabilization System - Slotted is intended to provide immobilization and stabilization of spinal segments 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, kyphosis, and failed previous fusion (pseudarthrosis).

    In addition, the DSS™ Stabilization System - Slotted is indicated for use in patients:

    • Who are receiving fusions with autogenous graft only; .
    • Who are having the device fixed or attached to the lumbar or sacral spine; .
    • . Who are having the device removed after the development of a solid fusion mass.

    Note: The Rigid Coupler and Slotted Coupler are not intended to be used together.

    Device Description

    The DSS™ Stabilization System is comprised of a variety of pedicle screws sizes, and couplers that act as longitudinal spacers that are uniquely fitted for each individual case. The pedicle screws and couplers are manufactured from medical grade titanium alloy (Ti6Al4V).

    The purpose of this Special 510(k) is to add a straight rod, straight rod with pan, and polyaxial screw to the DSS Stabilization System - Rigid. The modifications are intended to allow the operating surgeon to better accommodate patient anatomies with more construct options. The modifications do not affect the intended use of the device or alter the fundamental scientific technology of the device.

    AI/ML Overview

    1. Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Performance Testing per ASTM F1717)Reported Device Performance (DSS™ Stabilization System - Rigid)
    Static Compression Bending (comparable to predicate devices)Equivalent performance to predicate devices (K022949, K024096, K042962, K072022, K080241, K090099, K090408, K090408, and K101083)
    Static Torsion (comparable to predicate devices)Equivalent performance to predicate devices
    Dynamic Compression Bending (comparable to predicate devices)Equivalent performance to predicate devices

    2. Sample Size and Data Provenance for Test Set

    The provided document does not specify a separate "test set" in the context of clinical data or patient samples. The performance testing relies on mechanical testing per ASTM F1717. Therefore, the concept of sample size and data provenance from patient data is not applicable here. The "sample size" would refer to the number of devices tested under each mechanical test condition, which is not provided.

    3. Number of Experts and Qualifications for Ground Truth

    Again, this section is not applicable to the type of study presented. Ground truth in this context is established by standardized mechanical testing protocols (ASTM F1717) and comparison to the performance of previously cleared predicate devices, not by expert consensus on clinical findings.

    4. Adjudication Method for Test Set

    Not applicable. There is no clinical test set requiring adjudication in this submission.

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

    No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The submission focuses on mechanical substantial equivalence to predicate devices, not on the impact of the device on human reader performance.

    6. Standalone (Algorithm Only) Performance Study

    No, a standalone performance study (algorithm only without human-in-the-loop performance) was not done. This device is a physical medical implant, not an AI algorithm.

    7. Type of Ground Truth Used

    The ground truth used is based on established engineering standards and performance data of previously cleared predicate devices. Specifically, the "ground truth" for substantial equivalence is the demonstration that the DSS™ Stabilization System - Rigid performs equivalently to predicate devices under the mechanical stress tests outlined in ASTM F1717.

    8. Sample Size for Training Set

    Not applicable. This submission does not involve an AI algorithm or a "training set" in the context of machine learning. The "training" for this device's acceptance is based on its mechanical properties meeting established standards compared to existing devices.

    9. How Ground Truth for Training Set Was Established

    Not applicable. As there is no training set for an AI algorithm, the concept of establishing ground truth for it does not apply. The "ground truth" for the device's acceptance relates to its physical performance characteristics as determined by standardized testing methods.

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    K Number
    K101083
    Manufacturer
    Date Cleared
    2010-07-02

    (74 days)

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

    DSS STABILIZATION SYSTEM

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

    The DSS™ Stabilization System - Rigid is intended as a single-level system for noncervical pedicle fixation from the T4 to S1 vertebrae in skeletally mature patients to help provide immobilization and stabilization of spinal segments as an adjunct to fusion for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, kyphosis, and/or lordosis); tumor: pseudarthrosis; and failed previous fusion. The DSS™ Stabilization System - Rigid is intended to be used with autograft and/or allograft.

    The DSS™ Stabilization System - Slotted is intended to provide immobilization and stabilization of spinal segments 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, kyphosis, and failed previous fusion (pseudarthrosis).

    In addition, the DSS™ Stabilization System - Slotted is indicated for use in patients:
    Who are receiving fusions with autogenous graft only;
    Who are having the device fixed or attached to the lumbar or sacral spine;
    Who are having the device removed after the development of a solid fusion mass.

    Note: The Rigid Coupler and Slotted Coupler are not intended to be used together.

    Device Description

    The DSS™ Stabilization System -- Rigid is comprised of a variety of pedicle screws sizes, and couplers that act as longitudinal spacers that are uniquely fitted for each individual case. The pedicle screws and couplers are manufactured from medical grade titanium alloy (Ti6Al4V). This submission presents the addition of a 20mm long rigid coupler.

    AI/ML Overview

    The provided text describes a medical device, the DSS™ Stabilization System -- Rigid, and its 510(k) premarket notification (K101083). The submission focuses on demonstrating substantial equivalence to predicate devices based on non-clinical mechanical testing.

    Here's an analysis of the provided information against the requested categories:

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

    Acceptance CriteriaReported Device Performance
    Material: Medical grade titanium alloy (Ti6Al4V)Device is manufactured from medical grade titanium alloy (Ti6Al4V).
    Mechanical Performance (Static Flexion): Equivalent to predicate devices based on ASTM F1717.Testing performed in conjunction with ASTM F1717. Performance indicates equivalence to predicate devices.
    Mechanical Performance (Static Extension): Equivalent to predicate devices based on ASTM F1717.Testing performed in conjunction with ASTM F1717. Performance indicates equivalence to predicate devices.
    Mechanical Performance (Static Axial Rotation): Equivalent to predicate devices based on ASTM F1717.Testing performed in conjunction with ASTM F1717. Performance indicates equivalence to predicate devices.
    Mechanical Performance (Dynamic Compression Bending): Equivalent to predicate devices based on ASTM F1717.Testing performed in conjunction with ASTM F1717. Performance indicates equivalence to predicate devices.
    Indications for Use: Same as predicate devices.The device has the same indications for use as predicate devices.

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document describes non-clinical mechanical testing, not a clinical study involving human patients or data provenance in that sense. The "sample size" refers to the number of test articles used in the mechanical tests. The document states: "Static and dynamic mechanical testing was performed in conjunction with ASTM F1717." While it confirms that testing was done, the exact number of samples (test articles) used for each specific test (static flexion, extension, axial rotation, dynamic compression bending) is not explicitly stated.

    The data provenance is from non-clinical laboratory testing of the device components, not from human subjects or clinical data.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    This question is not applicable to this type of submission. The "ground truth" for mechanical testing is established by engineering standards (ASTM F1717) and the physical properties and behavior of the materials and device constructs, not by expert human interpretation.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    This question is not applicable. Adjudication methods are typically used in clinical studies for resolving discrepancies in expert opinions on clinical outcomes or image interpretations. For mechanical testing, the results are derived from physical measurements and engineering analyses, 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

    This question is not applicable. An MRMC study is a type of clinical study used to evaluate diagnostic imaging devices or AI algorithms where multiple human readers interpret cases. This submission is for a spinal implant, which undergoes mechanical testing and not typically MRMC studies for its premarket clearance.

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

    This question is not applicable. This device is a physical spinal implant, not an algorithm or AI system. Therefore, standalone algorithm performance is not relevant.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    The "ground truth" for this submission's non-clinical testing is based on established engineering standards and material science principles, specifically ASTM F1717. The performance of the device is measured against the expected mechanical properties and behavior defined by this standard and compared to the performance of predicate devices.

    8. The sample size for the training set

    This question is not applicable. This is not an AI/machine learning device that requires a training set. The "training" for a mechanical device is its design and manufacturing process according to engineering principles.

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

    This question is not applicable, as there is no "training set" in the context of this traditional medical device submission.

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    K Number
    K091944
    Date Cleared
    2009-08-03

    (34 days)

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

    MODIFICATION TO: DSS STABILIZATION SYSTEM

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

    DSSTM Stabilization System - Rigid: The DSS™ Stabilization System - Rigid is intended as a single-level system for noncervical pedicle fixation from the T4 to S1 vertebrac in skeletally mature patients to help provide immobilization and stabilization of spinal segments as an adjunct to fusion for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, kyphosis, and/or lordosis); tumor; pseudarthrosis; and failed previous fusion. The DSS™ Stabilization System - Rigid is intended to be used with autograft and/or allograft.

    DSSTM Stabilization System - Slotted: The DSS™ Stabilization System - Slotted is intended to provide immobilization and stabilization of spinal segments 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, kyphosis, and failed previous fusion (pseudarthrosis). In addition, the DSS™ Stabilization System - Slotted is indicated for use in patients: Who are receiving fusions with autogenous graft only; Who are having the device fixed or attached to the lumbar or sacral spine; . Who are having the device removed after the development of a solid fusion mass. Note: The Rigid Coupler and Slotted Coupler are not intended to be used together.

    Device Description

    The DSS™ Stabilization System is comprised of a variety of pedicle screws sizes, and couplers that act as longitudinal spacers that are uniquely fitted for each individual case. The pedicle screws and couplers are manufactured from medical grade titanium alloy (Ti6AI4V).

    AI/ML Overview

    The provided text describes a 510(k) submission for the DSS™ Stabilization System, a medical device. However, it does not include information about acceptance criteria, a specific study proving the device meets those criteria, or details regarding performance metrics, sample sizes, ground truth establishment, or expert involvement as typically found in clinical validation studies for AI/software devices.

    This document describes a spinal pedicle screw system, which is a physical implant, not an AI or software-based device. The approval process for such devices relies heavily on demonstrating substantial equivalence to predicate devices through design, function, material comparison, and mechanical testing, rather than clinical efficacy studies with ground truth derived from expert consensus or pathology, as would be the case for AI systems.

    Therefore, many of the requested categories are not applicable to the information contained in this 510(k) summary for the DSS™ Stabilization System.

    Here's a breakdown of what can be extracted or inferred from the provided text, and what cannot:

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

    Acceptance Criteria (Implied)Reported Device Performance
    Mechanical soundness comparable to predicate devices"Testing performed indicate that the DSS™ is as mechanically sound as predicate devices."
    Same indications for use as predicate devicesDSS™ Stabilization System has "the same indications for use" as predicate devices.
    Same design as predicate devicesDSS™ Stabilization System has "the same design" as predicate devices.
    Same function as predicate devicesDSS™ Stabilization System has "the same function" as predicate devices.
    Same materials used as predicate devicesDSS™ Stabilization System has "the same materials used" (medical grade titanium alloy) as predicate devices.
    FDA clearance for marketingDevice received 510(k) clearance, allowing it to proceed to market.
    Compatibility with specific surgical proceduresIntended as an adjunct to fusion, used with autograft and/or allograft.

    Explanation: For a physical device like a pedicle screw system, "acceptance criteria" primarily revolve around demonstrating substantial equivalence to already-approved predicate devices in terms of safety and effectiveness. This is typically achieved through comparisons of design, materials, function, and mechanical testing results against established benchmarks or the predicate devices themselves. The document states that the device was shown to be "substantially equivalent" and "as mechanically sound" as predicates.

    2. Sample sizes used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)

    • Not applicable / Not provided. The document describes mechanical testing, not a clinical study involving human patients or data sets. "Sample size" in this context would refer to the number of devices or components subjected to mechanical tests, which is not specified. There is no "data provenance" in the sense of patient data.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    • Not applicable / Not provided. This device's approval involved mechanical engineering assessments and regulatory review, not expert consensus on clinical data to establish a ground truth.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not applicable / Not provided. Adjudication methods are relevant for clinical studies where human experts interpret data, which is not described here.

    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

    • No. This is a physical medical device, not an AI system. Therefore, no MRMC study or assessment of AI assistance was performed.

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

    • Not applicable. This is not an algorithm or AI device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    • Not applicable for clinical ground truth. The "truth" for this device's approval revolved around engineering specifications, materials science, and mechanical performance validation, demonstrated to be equivalent to existing, legally marketed devices.

    8. The sample size for the training set

    • Not applicable. This device does not use a training set as it is not an AI/machine learning system.

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

    • Not applicable. No training set was used.
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    K Number
    K090099
    Date Cleared
    2009-06-19

    (155 days)

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

    DSS STABILIZATION SYSTEM

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

    The DSS™ Stabilization System - Rigid is intended as a single-level system for noncervical pedicle fixation from the T4 to S1 vertebrae in skeletally mature patients to help provide immobilization and stabilization of spinal segments as an adjunct to fusion for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, kyphosis, and/or lordosis); turnor; pseudarthrosis; and failed previous fusion. The DSS™ Stabilization System - Rigid is intended to be used with autograft and/or allograft.

    The DSSTM Stabilization System - Slotted is intended to provide immobilization and stabilization of spinal segments 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, kyphosis, and failed previous fusion (pseudarthrosis).

    In addition, the DSSTM Stabilization System - Slotted is indicated for use in patients:

    Who are receiving fusions with autogenous graft only;

    Who are having the device fixed or attached to the lumbar or sacral spine: ●
    Who are having the device removed after the development of a solid . fusion mass."

    Note: The Rigid Coupler and Slotted Coupler are not intended to be used together.

    Device Description

    The subject systems are comprised of a variety of pedicle screws and Couplers that act as longitudinal spacers. The systems are intended to be used with bone graft to provide immobilization and stabilization of a spinal segment as an adjunct to fusion.

    The subject systems are fabricated from wrought Ti-6A1-4V (ISO 5832-3 and ASTM F136).

    AI/ML Overview

    Here's an analysis of the provided text regarding the DSS™ Stabilization System and its submission for 510(k) clearance:

    Important Note: The provided text is a 510(k) Summary for a medical device. 510(k) clearances for devices like this (pedicle screw spinal systems) typically do NOT involve AI, machine learning, or software-based diagnostics. Instead, they focus on demonstrating substantial equivalence to a legally marketed predicate device, primarily through mechanical and material performance testing. Therefore, many of the questions related to AI/ML and human-in-the-loop performance will not be applicable.


    Acceptance Criteria and Device Performance (Based on provided text)

    Acceptance Criteria CategoryReported Device Performance (Summary from text)
    Material EquivalenceFabricated from wrought Ti-6A1-4V (ISO 5832-3 and ASTM F136), same as predicate.
    Design EquivalenceSame design as predicate devices.
    Function EquivalenceSame function as predicate devices.
    Intended Use EquivalenceSame intended use as predicate devices.
    Indications for Use EquivalenceSame indications for use as predicate devices.
    Performance Standards Testing"Testing performed indicates the subject systems are substantially equivalent to predicate devices."

    Explanation of "Acceptance Criteria" for this device: For a 510(k) pathway for a pedicle screw spinal system, "acceptance criteria" are not typically framed as specific statistical thresholds for diagnostic performance (like sensitivity/specificity for an AI device). Instead, they revolve around demonstrating substantial equivalence to a predicate device. This involves showing that the new device is as safe and effective as a legally marketed device that performs the same function. The primary evidence for this in the provided document is through:

    • Material composition: Matching established standards and predicate devices.
    • Design, Function, Intended Use, Indications for Use: Being demonstrably similar to predicate devices.
    • Performance Testing: While the details are not given, this would involve mechanical testing (e.g., static and dynamic compression, bending, torsion) to ensure the device meets or exceeds the mechanical properties and safety profiles of the predicate, as per relevant ASTM or ISO standards for spinal implants. The "Performance Standards" section vaguely states that testing confirms substantial equivalence.

    Study Details (Based on provided text)

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

      • Test Set Sample Size: Not applicable in the context of an AI/ML test set. For a mechanical device, testing would involve a sufficient number of devices/components to establish statistical significance for mechanical properties, but the specific number is not provided in this summary.
      • Data Provenance: Not applicable for AI/ML. The "data" here would be the results of mechanical and material tests, likely conducted in a controlled laboratory environment.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Not applicable. "Ground truth" in this context refers to regulatory compliance and mechanical performance, not a diagnostic assessment by experts. Design and manufacturing were likely overseen by engineers and quality control personnel.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • Not applicable.
    4. 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 mechanical implant, not an AI diagnostic tool.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • Not applicable. This is a mechanical implant.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • For this device, the "ground truth" for substantial equivalence is primarily based on:
        • Compliance with recognized standards: Material standards (ISO 5832-3, ASTM F136).
        • Reproducibility of mechanical properties: Laboratory-tested mechanical performance comparing the new device to the predicate device and relevant industry standards for spinal implant strength and durability.
        • Pre-clinical data: Likely involved bench testing and potentially biomechanical cadaver studies (though not explicitly detailed in the summary).
    7. The sample size for the training set:

      • Not applicable. There is no AI/ML training set.
    8. How the ground truth for the training set was established:

      • Not applicable. There is no AI/ML training set.

    Summary for K090099:

    This 510(k) summary is for a pedicle screw spinal system, a mechanical implant. The entire submission focuses on demonstrating substantial equivalence to already legally marketed predicate devices. This means proving that the new device has the same intended use, indications for use, technological characteristics (materials, design, function), and performs as safely and effectively as the predicate. The "study" here refers to the engineering and performance testing that verifies the device's mechanical integrity and material compliance, not a clinical trial or an AI/ML validation study.

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    K Number
    K090408
    Date Cleared
    2009-03-20

    (30 days)

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

    MODIFICATION TO: DSS STABILIZATION SYSTEM

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

    The DSS™ Stabilization System - Rigid is intended as a single-level system for noncervical pedicle fixation from the T4 to S1 vertebrae in skeletally mature patients to help provide immobilization and stabilization of spinal segments as an adjunct to fusion for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, kyphosis, and/or lordosis); tumor; pseudarthrosis; and failed previous fusion. The DSS™ Stabilization System - Rigid Coupler is intended to be used with autograft and/or allograft.

    Device Description

    This 510(k) adds additional screw sizes to the DSS™ Stabilization System. The DSSTM Stabilization System is comprised of a variety of pedicle screws sizes, and couplers that act as longitudinal spacers that are uniquely fitted for each individual case. The pedicle screws and couplers are manufactured from medical grade titanium alloy (Ti6Al4V).

    AI/ML Overview

    Here's an analysis of the provided text regarding the Paradigm Spine DSS™ Stabilization System and its 510(k) submission (K090408), focusing on the acceptance criteria and the study (or lack thereof) proving the device meets them:

    No clinical performance study or specific acceptance criteria are described in the provided 510(k) summary documents.

    The provided documents are a 510(k) summary and the FDA's clearance letter. For a Class III device like a pedicle screw spinal system, the FDA typically determines substantial equivalence based on a comparison to a legally marketed predicate device. This often involves demonstrating equivalent technological characteristics and performance through non-clinical (e.g., mechanical) testing, rather than extensive clinical efficacy trials, especially for devices introducing minor modifications (like additional screw sizes as stated here).

    Therefore, many of the requested categories related to clinical study design and performance metrics cannot be filled from the given text.


    1. Table of Acceptance Criteria and Reported Device Performance

    Based on the provided documents, specific acceptance criteria for clinical performance and reported device performance are NOT detailed.

    The approval is based on "substantial equivalence" to a predicate device (K080241). The performance stated is that:

    Acceptance Criteria (Implied)Reported Device Performance
    Mechanical Soundness (compared to predicate devices)"Testing performed indicate that the DSS™ is as mechanically sound as predicate devices."
    Indications for Use (matching predicate device)"DSS™ Stabilization System was shown to be substantially equivalent to previously cleared devices (K080241) and has the same indications for use..."
    Design, Function, and Materials (matching predicate device)"...has the same indications for use, design, function, and materials used."

    Note: "Mechanical Soundness" implies that the device met certain mechanical testing standards (e.g., fatigue, static strength), but the specific criteria (e.g., force levels, cycles) are not provided in this summary.


    2. Sample Size Used for the Test Set and the Data Provenance

    • Sample Size for Test Set: Not applicable/not provided for clinical performance. The "test set" would refer to mechanical testing samples, which are not detailed here.
    • Data Provenance: Not applicable/not provided for clinical performance. The mechanical testing data would likely be from the manufacturer's internal labs.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts

    • Not applicable, as no clinical test set requiring expert ground truth establishment is described.

    4. Adjudication Method for the Test Set

    • Not applicable, as no clinical test set requiring adjudication is described.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    • No, an MRMC comparative effectiveness study was not done or described in these documents. This is a mechanical orthopedic device, not an imaging AI diagnostic device, so MRMC studies are generally not relevant for 510(k) clearance of this type of product.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    • Not applicable. This is a medical implant device, not an algorithm.

    7. The Type of Ground Truth Used

    • Not applicable for clinical performance. For mechanical testing, the "ground truth" would be the engineering specifications and performance benchmarks derived from the predicate device and established standards for pedicle screw spinal systems.

    8. The Sample Size for the Training Set

    • Not applicable. This is a medical implant device, not an AI/ML algorithm that requires a training set.

    9. How the Ground Truth for the Training Set Was Established

    • Not applicable. This is a medical implant device, not an AI/ML algorithm.

    Summary of 510(k) Clearance for K090408:

    The K090408 submission was a Special 510(k), specifically to add additional screw sizes to an already cleared DSS™ Stabilization System (predicate K080241). The primary basis for clearance was a demonstration of substantial equivalence to the predicate device in terms of:

    • Mechanical Soundness: Testing indicated the new screw sizes were "as mechanically sound as predicate devices."
    • Indications for Use: The system maintained the same indications as the predicate.
    • Design, Function, and Materials: These were also consistent with the predicate.

    The FDA's review concluded that there was a reasonable likelihood that the device could be used for spinal stabilization without fusion, which could cause harm. Therefore, a specific Warning was mandated in the labeling: "The safety and effectiveness of this device has not been established for the intended use of spinal stabilization without fusion. This device is only intended to be used when fusion with autogenous bone graft is being performed at all instrumented levels." This indicates a careful consideration of the intended use and potential off-label use, even in the absence of a de novo clinical trial for this specific 510(k).

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    K Number
    K080963
    Manufacturer
    Date Cleared
    2008-05-02

    (28 days)

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

    DSS STABILIZATION SYSTEM

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

    The DSSTM Stabilization System is intended to provide immobilization and stabilization of spinal segments 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, kyphosis, and failed previous fusion (pseudarthrosis).

    In addition, the DSSTM Stabilization System is indicated for use in patients:

    • . Who are receiving fusions with autogenous graft only;
    • Who are having the device fixed or attached to the lumbar or sacral spine; . ●
    • Who are having the device removed after the development of a solid fusion mass. .
    Device Description

    The DSS™ Stabilization System is comprised of a variety of pedicle screws sizes, and couplers that act as longitudinal spacers that are uniquely fitted for each individual case. The pedicle screws and couplers are manufactured from medical grade titanium alloy (Ti6Al4V).

    AI/ML Overview

    The provided text is a 510(k) summary for the Paradigm Spine DSS™ Stabilization System, a medical device. This type of submission focuses on demonstrating substantial equivalence to a predicate device rather than conducting extensive clinical studies with specified acceptance criteria as one might find for a novel drug or a high-risk device.

    Based on the provided document, here's an analysis of the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance CriteriaReported Device Performance
    Mechanical Soundness (Implicit based on predicate comparison)"Testing performed indicate that the DSS™ is as mechanically sound as predicate devices."
    Indications for Use Equivalence"DSS™M Stabilization System was shown to be substantially equivalent to previously cleared devices and has the same indications for use..."
    Design Equivalence"...design..."
    Function Equivalence"...function..."
    Material Equivalence"...and materials used."

    Explanation: The acceptance criteria for a 510(k) submission like this are centered around demonstrating substantial equivalence to a predicate device. This means showing that the new device is as safe and effective as a legally marketed device that is not subject to premarket approval. The primary "performance" is its equivalence to existing, cleared devices, particularly in mechanical properties and intended use. Specific quantitative performance metrics or thresholds are not detailed in this summary for the DSS™ system.

    2. Sample Size Used for the Test Set and the Data Provenance

    The document does not describe a clinical study with a "test set" in the traditional sense of evaluating patient outcomes with the device. The "testing" mentioned refers to mechanical testing.

    • Sample Size: Not specified for mechanical testing.
    • Data Provenance: Not specified, but generally, mechanical testing data for device submissions originates from laboratory tests, not human subjects.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts

    Not applicable. The submission focuses on mechanical equivalence, not human-read interpretations or diagnostic accuracy.

    4. Adjudication Method for the Test Set

    Not applicable. There's no mention of a test set requiring adjudication by experts.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No. This document does not describe an MRMC comparative effectiveness study. The focus is on demonstrating mechanical and functional equivalence to predicate devices, not on comparing performance with and without AI assistance or between different human readers.

    6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done

    No. This device is a pedicle screw spinal system, a physical implant, not an AI algorithm. Therefore, a standalone algorithm performance study is not applicable.

    7. The Type of Ground Truth Used

    The "ground truth" here is the established safety and effectiveness of the identified predicate devices. The DSS™ Stabilization System's acceptability is based on its demonstrated equivalence to these already cleared devices, particularly in mechanical characteristics and intended use.

    8. The Sample Size for the Training Set

    Not applicable. As a physical medical device, there is no "training set" in the context of machine learning or AI models.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable, as there is no "training set" for this type of device.


    Summary of Device Acceptance:

    The Paradigm Spine DSS™ Stabilization System was accepted by the FDA based on a demonstration of substantial equivalence to already legally marketed predicate devices. The key "acceptance criteria" were implied to be:

    • Mechanical Soundness: The device performs at least as well mechanically as predicate devices.
    • Indications for Use: The device shares the same intended uses as predicate devices.
    • Design, Function, and Materials: The device's fundamental aspects are comparable to predicate devices.

    The "study" proving this was primarily mechanical testing (which "indicate[s] that the DSS™ is as mechanically sound as predicate devices") and a comparison of the device's characteristics and intended use to those of predicate devices. The specific details of this mechanical testing (e.g., sample size, methods, results) are not provided in this public summary but would have been part of the full 510(k) submission.

    A crucial limitation added by the FDA regarding the device's labeling is: "The safety and effectiveness of this device for the indication of spinal stabilization without fusion have not been established." This indicates that while substantial equivalence was found for its use as an adjunct to fusion, its standalone use for stabilization was not supported by the provided evidence.

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