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510(k) Data Aggregation

    K Number
    K103671
    Manufacturer
    Date Cleared
    2011-07-21

    (217 days)

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

    GENESYS SPINE TILOCK SYSTEM

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

    The TiLock Pedicle Screw System is intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of thoracic, lumbar, and sacral spine: degenerative disc disease (DDD) (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; pseudoarthrosis; and failed previous fusion.

    Device Description

    The Genesys Spine TiLock Pedicle Screw System is comprised of polyaxial screws (standard and cannulated) and monoaxial screws in various lengths and diameters, lock plugs, cross-links, tulips and rods in various lengths. The Til.ock System allows the placement of either 5.5mm titanium or 5.5mm cobalt chromium rods. The TiLock cannulated polyaxial screws may be implanted via a minimally invasive technique. Manual instrumentation for implantation of the svstem is available for both conventional and minimally invasive procedures. The minimally invasive procedure is performed using k-wire and fluoroscopy, which allows the implanting surgeon to employ two smaller incisions rather than a longer midline incision.

    The subject device is the result of modifications to the existing Genesys Spine TiLock rod system which resulted in the inclusion of a 5.5mm straight and prebent cobalt chromium rod to the system. The subject device shares the same intended use and fundamental scientific technology as the predicate device.

    AI/ML Overview

    The Genesys Spine TiLock Pedicle Screw System is a medical device. Here's a breakdown of the information regarding its acceptance criteria and supporting studies:

    1. Acceptance Criteria and Reported Device Performance

    The provided document describes the device's substantial equivalence to predicate devices, rather than establishing specific quantitative performance acceptance criteria for diagnostic output. The primary "acceptance criteria" here is demonstrated substantial equivalence in terms of mechanical and material properties, meaning the modified device performs similarly to or better than previously approved devices.

    Acceptance Criteria (Implied)Reported Device Performance
    Mechanical properties (e.g., strength, durability, fatigue resistance)Test results demonstrate that the TiLock System is substantially equivalent to the predicate device. Finite element and material property analysis as well as design verification results demonstrate that the proposed device is substantially equivalent to the predicate device.
    Material composition for biocompatibility and performance"material property analysis" demonstrating substantial equivalence to predicate device. Inclusion of a 5.5mm straight and prebent cobalt chromium rod, implying material properties are comparable or superior to predicate's rod materials.
    Intended UseShares the same intended use as the predicate device.
    Fundamental Scientific TechnologyShares the same fundamental scientific technology as the predicate device.

    2. Sample Size and Data Provenance for Test Set

    • Test Set Sample Size: Not explicitly stated as a distinct "test set" in the context of typical AI algorithm evaluation. The evaluation is based on design verification results, finite element analysis, and material property analysis. These generally do not involve a "sample size" of patient data or images in the same way. Instead, they refer to the number of simulations, physical tests, or material samples analyzed. The document does not specify these numbers.
    • Data Provenance: Not applicable in the context of this type of device submission. The evaluation is non-clinical, focusing on engineering and material properties, not patient data.

    3. Number of Experts and Qualifications for Ground Truth (Test Set)

    • Number of Experts: Not applicable. Ground truth, in this context, refers to established engineering standards, material science principles, and mechanical testing protocols.
    • Qualifications of Experts: Not explicitly stated. However, it's inferred that the "design verification results" and "finite element and material property analysis" were conducted by qualified engineers and material scientists.

    4. Adjudication Method for Test Set

    • Adjudication Method: Not applicable. The evaluation relies on objective engineering and material testing, not subjective human assessment needing adjudication.

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

    • MRMC Study Done: No. This device is a pedicle screw system, not an AI-assisted diagnostic tool.

    6. Standalone (Algorithm Only) Performance Study

    • Standalone Study Done: No. This device is a physical medical implant, not an algorithm.

    7. Type of Ground Truth Used

    • Ground Truth Type:
      • Engineering Standards and Specifications: Mechanical strength, fatigue limits, material compatibility, and overall design integrity according to established biomechanical and medical device standards.
      • Predicate Device Performance: The primary ground truth is the performance characteristics of the legally marketed predicate devices, to which the new device is compared for substantial equivalence.

    8. Sample Size for Training Set

    • Training Set Sample Size: Not applicable. This device is not an AI algorithm that requires a "training set" of data.

    9. How Ground Truth for Training Set was Established

    • Ground Truth Establishment for Training Set: Not applicable, as there is no training set for this type of device.

    Summary of the Study that Proves the Device Meets Acceptance Criteria:

    The study that proves the Genesys Spine TiLock Pedicle Screw System meets its (implied) acceptance criteria is a non-clinical engineering and material science evaluation. This evaluation aimed to demonstrate substantial equivalence to existing predicate devices.

    The key components of this study were:

    • Finite Element Analysis (FEA): This is a computational method used to predict how a product reacts to real-world forces, heat, vibration, fluid flow, and other physical effects. It simulates the mechanical behavior of the pedicle screw system under various loads and conditions to ensure its structural integrity.
    • Material Property Analysis: This involves characterizing the mechanical, chemical, and physical properties of the materials used in the device (e.g., titanium, cobalt chromium). This ensures the materials meet required standards for strength, biocompatibility, and durability.
    • Design Verification Results: This encompasses a range of tests and analyses to confirm that the device design meets its intended specifications and functions as expected. This could include bench testing for mechanical performance, dimensional analysis, and other forms of verification.

    Conclusion: The regulatory submission states that these non-clinical performance data (finite element, material property analysis, and design verification results) were sufficient to demonstrate that the Genesys Spine TiLock Pedicle Screw System is substantially equivalent to its predicate devices. This means that, based on these engineering and material science studies, the device is considered as safe and effective as other devices already legally marketed for the same intended use. No clinical studies were deemed necessary for this particular submission.

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