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510(k) Data Aggregation
(246 days)
WASTON General Spinal System
The WASTON General Spinal System is intended for posterior pedicle screw fixation of the non-cervical posterior spine in skeletally mature patients. It provides stabilization of spinal segments as an adjunct to fusion in the treatment of the following acute and chronic instabilities deformities: (1) trauma (i.e. fracture or dislocation), (2) curvatures (scoliosis, kyphosis, and/or lordosis), (3) spinal tumor, (4) failed previous fusion, (5) spinal stenosis. It is not intended for pedicle screw fixation above T8.
The WASTON General Spinal System consists of Fixed-Angle Screws, Fixed-Angle Reduction Screws, Rods, Crosslink and Set Screws. The proposed general spinal system is made of Titanium Alloy (Ti6Al4VELI), which meets ASTM F136-02a, Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications, which are widely used for surgical implants with well-known biocompatibility. The proposed devices are provided non-sterile. It is required to be sterilized via autoclave method to reach a SAL of 10th by the hospital prior to surgery. The recommended sterilization method was validated per ISO 17665-1: 2006 Sterilization of health care products -- Moist heat -- Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices.
The document provided is a 510(k) premarket notification for the WASTON General Spinal System, identifying it as a Class II medical device. The submission primarily focuses on demonstrating substantial equivalence to a predicate device (Trauson General Spinal System, K082617) through non-clinical testing.
Here's an analysis of the acceptance criteria and study information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Standard) | Reported Device Performance |
---|---|
ASTM F1717-14: Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model, including: | The non-clinical tests demonstrated that the proposed device met "all design specifications" and complied with the ASTM F1717-14 standard. Specific quantitative results (e.g., maximum load, displacement, cycles to failure) are not provided in this summary. The summary states that the tests included: |
- Static compression bending test | (Implied compliance, no specific numeric results provided) |
- Dynamic compression bending test | (Implied compliance, no specific numeric results provided) |
- Static torsion test | (Implied compliance, no specific numeric results provided) |
Sterilization validation per ISO 17665-1: 2006 | The recommended sterilization method (autoclave) was validated per ISO 17665-1: 2006 to achieve a Sterility Assurance Level (SAL) of 10^-6, ensuring the devices are sterile prior to use. |
Biocompatibility (Material) | The device is made of Titanium Alloy (Ti6Al4VELI), which meets ASTM F136-02a, and is noted for its "well-known biocompatibility" for surgical implant applications. |
Substantial Equivalence to predicate (K082617) through comparison of technological characteristics and intended use. | Based on the comparison of product code, regulation number, intended use (with minor differences noted but deemed equivalent for SE), configurations (with minor differences), material, sterilization, and single-use status, the proposed device was determined to be "Substantially Equivalent (SE)" to the predicate. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: The document does not specify the exact sample size for the mechanical tests conducted per ASTM F1717-14. It only states that "Non clinical tests were conducted." Typically, these tests involve multiple samples for each component or construct configuration, but the precise numbers are not disclosed in this summary.
- Data Provenance: The device manufacturer is Changzhou Waston Medical Appliance Company, Limited, located in China. Therefore, the non-clinical test data was likely generated in China, associated with the manufacturer or a contracted testing facility. The data is retrospective in the sense that the tests were completed before the 510(k) submission.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
- This information is not applicable to this submission. The "test set" in this context refers to non-clinical, mechanical performance testing of a spinal implant system. The "ground truth" is established by adherence to a recognized standard (ASTM F1717-14) and the physical properties of the materials and device design, rather than expert interpretation of data.
4. Adjudication Method for the Test Set
- This information is not applicable to this submission. Adjudication methods like 2+1 or 3+1 are typically used in clinical studies for interpreting human-read data or clinical endpoints. For mechanical testing against a standard, the results are objectively measured and compared to the standard's pass/fail criteria, often requiring a pass for all tested samples.
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. The document explicitly states: "No clinical study is included in this submission." This type of study is relevant for AI-powered diagnostic or interpretive devices, which is not the case for a spinal implant system.
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 device is a physical spinal implant system, not an algorithm or AI-based diagnostic tool. Therefore, a standalone algorithm performance study would not be relevant.
7. The Type of Ground Truth Used
- For the non-clinical testing, the "ground truth" is typically defined by established engineering standards and material specifications. The device's performance is compared against the requirements and methodologies outlined in:
- ASTM F1717-14 for mechanical performance (static compression bending, dynamic compression bending, static torsion).
- ASTM F136-02a for material composition and properties.
- ISO 17665-1: 2006 for sterilization validation.
8. The Sample Size for the Training Set
- This information is not applicable to this submission. "Training set" refers to data used to train machine learning models. As this device is a physical spinal implant system and does not involve AI or algorithms, there is no training set in this context.
9. How the Ground Truth for the Training Set was Established
- This information is not applicable as there is no training set for this type of device.
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(247 days)
GENERAL SPINAL SYSTEM
The General System is intended for posterior pedicle screw fixation of the non-cervical posterior spine in skeletally mature patients. It provides stabilization of spinal segments as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities: (1) trauma (i.e. fracture or dislocation), (2) curvatures (scoliosis, kyphosis, and/or lordoss), (3) spinal tumor, (4) failed previous fusion, (6) spinal stenosus. It is not intended for pedicle screw fixation above T8. This device may be used with autograft and/or allograft.
The General Spinal System consists of Fixed-Angle Reduction Screws. Rods, Cross Link and set screws. It is made of Titanium Alloy (Ti6Al4VELI), which meets ASTM F136-02a, Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications, which are widely used for surgical implants with well known biocompatibility. The proposed devices are provided non-sterile. It is required to be sterilized via autoclave method to reach a SAL of 10 by the hospital prior to surgery. The recommended sterilization method was validated per ISO 17665-1: 2006 Sterilization of health care products -- Moist heat -- Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices
The provided document is a 510(k) summary for the "General Spinal System," a pedicle screw spinal system. It describes the device, its intended use, and states that non-clinical tests were conducted to demonstrate substantial equivalence to predicate devices. However, the document does not contain specific acceptance criteria, reported device performance metrics, detailed study designs (such as sample sizes, ground truth establishment, or expert qualifications), or the results of comparative effectiveness studies (MRMC) or standalone algorithm performance studies that would be necessary to answer the questions thoroughly.
Therefore, I can only provide information based on what is available in the document.
Detailed Breakdown based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state quantitative acceptance criteria in terms of specific performance metrics (e.g., specific load endurance values, displacement limits) that a device must meet, nor does it report specific numerical performance results for the device against such criteria.
Instead, the document states: "Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standard: ASTM F1717-04, Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model, including the following items: Static compression bending test; Dynamic compression bending test; Static torsion test."
This implies that the acceptance criteria are adherence to the ASTM F1717-04 standard's methodologies and achieving comparable performance to the predicate device(s) within the scope of these tests. Without specific data, a table cannot be constructed with numerical values.
Acceptance Criteria (Implied) | Reported Device Performance (Summary) |
---|---|
Compliance with ASTM F1717-04 for Spinal Implant Constructs in a Vertebrectomy Model | The device's non-clinical tests demonstrated compliance with ASTM F1717-04 for static compression bending, dynamic compression bending, and static torsion tests. The device was deemed Substantially Equivalent (SE) to predicate devices based on these tests. |
2. Sample size used for the test set and the data provenance
The document describes non-clinical mechanical tests. It does not involve human data or test sets in the context of clinical trials. Therefore, "sample size used for the test set" and "data provenance (e.g. country of origin of the data, retrospective or prospective)" are not applicable in the context of this device's testing as described. The testing was likely conducted in a laboratory setting.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This question is not applicable as the document describes non-clinical mechanical testing, not a study involving ground truth established by experts (e.g., radiologists, pathologists). The "ground truth" for mechanical testing is typically defined by the test standard (e.g., ASTM F1717-04) and the physical properties observed.
4. Adjudication method for the test set
This question is not applicable for the same reason as points 2 and 3. Adjudication methods like 2+1 or 3+1 are used in clinical studies or expert consensus scenarios, not for mechanical bench 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 question is not applicable. The device is a "General Spinal System" (a pedicle screw spinal system), which is a physical implant, not an AI or imaging diagnostic device. Therefore, MRMC studies and AI assistance are irrelevant to this device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This question is not applicable. The device is a physical medical implant, not an algorithm or software.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For the non-clinical tests described, the "ground truth" refers to the established performance characteristics and requirements outlined in the ASTM F1717-04 standard for spinal implant constructs, as well as the observed mechanical properties (e.g., strength, stiffness, fatigue life) of the tested device and its predicate(s). It is purely objective mechanical measurement, not a subjective "truth" established by experts or clinical outcomes.
8. The sample size for the training set
This question is not applicable. The document describes the testing of a physical medical device, not an AI/ML algorithm that requires a "training set."
9. How the ground truth for the training set was established
This question is not applicable for the same reason as point 8.
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(89 days)
GENERAL SPINAL SYSTEM
The General Spinal System is intended for posterior pedicle screw fixation of the non-cervical posterior spine in skeletally mature patients. It provides stabilization and immobilization of spinal segments as an adjunct to fusion in the treatment of the following acute and chronic instabilities deformities: (1) trauma (i.e. fracture or dislocation), (2) curvatures (scoliosis, kyphosis, and/or lordosis), (3) spinal tumor, (4) failed previous fusion, (5) pseudarthrosis, (6) spinal stenosis. It is not intended for pedicle screw fixation above T8.
The General Spinal System consists of Fixed-Angle Screws, Fix-Angle Reduction Screws, Hooks, Rods, Cross Link and Set Screws. It is made of Titanium Alloy (Ti6Al4VELI), which meets ASTM F136-02a, Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Allov for Surgical Implant Applications. which are widely used for surgical implants with well known biocompatibility. The proposed devices are provided non-sterile. It is required to be sterilized via autoclave method to reach a SAL of 10 by the hospital prior to surgery. The recommended sterilization method was validated per ISO 17665-1: 2006 Sterilization of health care products -- Moist heat -- Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices
This document describes the General Spinal System, a pedicle screw spinal system. The primary method of demonstrating acceptance criteria for this device is through non-clinical testing, specifically mechanical performance testing, and comparison to a legally marketed predicate device to establish substantial equivalence.
1. Table of Acceptance Criteria and Reported Device Performance
Parameter | Acceptance Criteria (Standard) | Reported Device Performance (Test Results) |
---|---|---|
Mechanical Performance | ASTM F1717-04: Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model | Complies with the standard. |
Static compression bending | As per ASTM F1717-04 | Met specifications. |
Dynamic compression bending | As per ASTM F1717-04 | Met specifications. |
Static torsion | As per ASTM F1717-04 | Met specifications. |
Material Biocompatibility | ASTM F136-02a: Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications | Made of Titanium Alloy (Ti6Al4VELI) meeting this standard, confirming well-known biocompatibility. |
Sterilization Efficacy | ISO 17665-1:2006 Sterilization of health care products -- Moist heat -- Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices | Recommended sterilization method was validated to reach a SAL (Sterility Assurance Level) of 10^-6. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: The document does not specify exact sample sizes (e.g., number of constructs tested) for each mechanical test performed under ASTM F1717-04. It only states that "Non clinical tests were conducted to verify that the proposed device met all design specifications."
- Data Provenance: The tests are non-clinical (laboratory tests) conducted by Tianjin Walkman Biomaterial Co., Ltd. in China. The data provenance is internal testing, not patient data.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications
- This information is not applicable. The "ground truth" for non-clinical performance evaluations of medical devices like spinal systems is typically established by recognized national/international standards (e.g., ASTM, ISO), which define test methodologies, acceptance criteria, and performance limits. These standards are developed and maintained by committees of experts, but specific "experts" assigned to establish "ground truth" for a particular device's test set are not mentioned or required in this context.
4. Adjudication Method for the Test Set
- This information is not applicable. The non-clinical tests involve objective measurements (e.g., load, displacement) against specified performance criteria, rather than subjective interpretation requiring adjudication among multiple parties.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
- No, a multi-reader multi-case (MRMC) comparative effectiveness study was not performed. This type of study is relevant for diagnostic imaging devices where human interpretation of images is a key factor. This submission pertains to a surgical implant (pedicle screw spinal system), where performance is assessed through mechanical testing and material properties.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- This is not applicable. The device is a physical surgical implant, not a software algorithm.
7. The Type of Ground Truth Used
- The "ground truth" for the device's performance in this context is defined by established engineering and material standards. Specifically:
- Mechanical Integrity: ASTM F1717-04 defines the "ground truth" for appropriate mechanical performance characteristics (static/dynamic bending, torsion) expected of spinal implant constructs.
- Material Biocompatibility: ASTM F136-02a defines the "ground truth" for the material properties and biocompatibility of the titanium alloy used.
- Sterilization: ISO 17665-1:2006 defines the "ground truth" for a validated sterilization process to achieve a specified Sterility Assurance Level.
8. The Sample Size for the Training Set
- This information is not applicable. The device is a physical medical device, not an AI/ML algorithm that requires a training set. The design and manufacturing process are informed by general engineering principles and material science, not a data-driven "training" process in the AI sense.
9. How the Ground Truth for the Training Set Was Established
- This information is not applicable as there is no "training set" for this device.
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(128 days)
TRAUSON GENERAL SPINAL SYSTEM (GSS)
Transon General Spinal System (GSS) is intended for posterior pedicle screw fixation (GSS-VII can be applied for anterior or anterolateral fixation) of the non-cervical posterior spine in skeletally mature patients. It provides stabilization and immobilization of spinal segments as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities.
When used as a posterior spine thoracic/lumbar system, Trauson General Spinal System (GSS) is indicated for one or more of the following: (1) trauma (i.e. fracture or dislocation), (2) curvatures (scoliosis, and/or lordosis), (3) spinal tumor, (4) failed previous fusion (5) pscudarthrosis, (6) spinal stenosis.
Trauson General Spinal System (GSS) is not intended for pedicle screw fixation above T8.
The applicant device of Trauson General Spinal System (GSS) made of Titaniuim Alloy (Ti-6AL-4V) that meet ASTM 136 is intended for posterior pedicle screw fixation of the non-cervical posterior spine in skeletally mature patients.
The applicant devices are not provided sterile. The materials are wildly used in the industry with well know biocompatibility. No new materials are used in the development of this implant. No surface modified or coated.
All variants use the same material, same design principle and are constant thickness.
No chemical for the enhancement of its clinical performance is applied on or incorporated into applicant device.
The provided text is a 510(k) summary for the Trauson General Spinal System (GSS), a medical device. This type of submission focuses on demonstrating substantial equivalence to a predicate device rather than presenting a detailed acceptance criteria table and a study proving device performance against those criteria.
Therefore, the input does not contain the information requested in the prompt (acceptance criteria, device performance table, sample sizes, expert details, adjudication methods, MRMC studies, standalone performance, ground truth types, or training set details). The document states "Performance tests demonstrate that the specifications of the proposed device meet its design input," but it does not elaborate on what those specifications or performance tests were.
Without explicit information from the provided text, I cannot complete the requested tables and descriptions based on this submission. This is a common characteristic of 510(k) summaries, which aim to establish equivalence rather than present full validation study results.
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