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510(k) Data Aggregation

    K Number
    K171567
    Date Cleared
    2017-08-28

    (90 days)

    Product Code
    Regulation Number
    888.3080
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    IRIX-A Lumbar Integrated Fusion System

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

    The IRIX-A™ Lumbar Integrated Fusion System is a stand-alone intervertebral body fusion device intended for use in patients with degenerative disc disease (DDD) at one (1) or two (2) contiguous levels of the lumbosacral spine (L2-S1 inclusive). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. These patients should be skeletally mature and have had at least six (6) months of non-operative treatment. In addition, these patients may have had a previous non-fusion spinal surgery at the involved level(s) and may have had up to a Grade I spondylolisthesis or retrolisthesis at the involved level(s). The IRIX-A™ System is intended to be used with autograft and/or allograft comprised of cancellous bone graft material, and is to be used with three titanium alloy screws included as part of the system.

    Hyperlordotic implants >20° are intended for use with supplemental fixation (e.g. facet screws or posterior fixation).

    Device Description

    The IRIX-A™ Lumbar Integrated Fusion System is a stand-alone intervertebral fusion device to restore biomechanical height and act as an aid in fusion of the lumbar spine in anterior discectomy procedures. The device is generally boxed shaped with teeth on the superior and inferior faces of the device. The IRIX-A™ implant is manufactured from both titanium alloy (Ti6AI4V) in accordance with ASTM F136 and Invibio PEEK Optima LT1 in accordance with ASTM F2026, or from Ti6Al4V titanium alloy alone. The device will be supplied with the option of having the superior and inferior surfaces of the device plasma coated with medical-grade commercially pure titanium (CP Ti) per ASTM F1580.

    The device is secured in location through the use of bone screws, also manufactured from titanium alloy (Ti6Al4V) per ASTM F136. The devices are provided in various sizes, and screws are offered in multiple lengths to adjust for variations in patient anatomy. The spacers of the IRIX-A™ System are supplied clean and STERILE. The screws and accompanying instruments of the IRIX™-A System are provided clean and non-sterile.

    The system does not contain software/firmware or electrical equipment.

    AI/ML Overview

    The provided document is a 510(k) Pre-market Notification from the FDA for a medical device called the IRIX-A™ Lumbar Integrated Fusion System. This submission focuses on establishing substantial equivalence to existing predicate devices, rather than a clinical study evaluating the device's diagnostic performance against specific acceptance criteria for AI/software-based devices. Therefore, much of the requested information regarding acceptance criteria for device performance in a clinical context, sample sizes for test and training sets, expert qualifications, and ground truth establishment, is not applicable or not present in this type of regulatory document.

    However, I can extract information related to the performance data provided within this 510(k) summary for non-clinical testing.

    Here's a breakdown of the available information:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance Criteria (from testing standards)Reported Device Performance
    ASTM F2077: Static and dynamic compression testing (specific values not provided in this document)Meets or exceeds the performance of the predicate device.
    ASTM F2267: Subsidence (specific values not provided in this document)Meets or exceeds the performance of the predicate device.
    Expulsion as recommended by FDA (specific methodology/values not provided in this document)Meets or exceeds the performance of the predicate device.

    Note: The document states the device "meets or exceeds the performance of the predicate device" for these tests, implying that the acceptance criteria are based on the performance of the predicate device as established through the same ASTM standards and FDA recommendations.

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

    • Test set sample size: Not applicable. This document describes non-clinical mechanical testing, not a clinical study involving a test set of data.
    • Data provenance: Not applicable. The testing is described as "Nonclinical testing" and performed on the device itself.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Not applicable. Ground truth for clinical data is not relevant to this non-clinical mechanical testing.

    4. Adjudication method for the test set:

    • Not applicable.

    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 not an AI/software-based diagnostic device, nor a comparative effectiveness study involving human readers.

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

    • Not applicable. This is not an algorithm-only device.

    7. The type of ground truth used:

    • For the non-clinical performance data: The "ground truth" or reference for performance is the established performance characteristics of the predicate device under the specified ASTM standards and FDA recommendations for static and dynamic compression, subsidence, and expulsion.

    8. The sample size for the training set:

    • Not applicable. This product does not involve machine learning or a "training set."

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

    • Not applicable.

    Summary based on the provided document:

    The IRIX-A™ Lumbar Integrated Fusion System is a physical medical device (intervertebral body fusion device), not an AI/software-based diagnostic tool. The regulatory submission (510(k)) aims to demonstrate substantial equivalence to legally marketed predicate devices. This is achieved through non-clinical performance testing (mechanical/physical tests) rather than clinical studies involving patient data and diagnostic performance metrics like sensitivity, specificity, or reader studies.

    The performance data supplied focuses on:

    • ASTM F2077: Static and dynamic compression testing
    • ASTM F2267: Subsidence
    • Expulsion testing as recommended by FDA

    The conclusion is that the subject device "meets or exceeds the performance of the predicate device" for these tests, indicating that its mechanical integrity and function are comparable or superior, and it "does not introduce any new risks." The predicate device itself acts as the benchmark for establishing acceptable performance under these tests.

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    K Number
    K133947
    Date Cleared
    2014-07-29

    (218 days)

    Product Code
    Regulation Number
    888.3080
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    IRIX-A LUMBAR INTEGRATED FUSION SYSTEM

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

    The Irix-A Lumbar Integrated Fusion System is a stand-alone intervertebral body fusion device intended for use in patients with degenerative disc disease (DDD) at one (1) or two (2) contiguous levels of the lumbosacral spine (L2-S1 inclusive). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. These patients should be skeletally mature and at least six (6) months of non-operative treatment. In addition, these patients may have had a previous non-fusion spinal surgery at the involved level(s) and may have had up to a Grade I spondylolisthesis or retrolisthesis at the involved level(s). The Irix-A System is intended to be used with autogenous bone graft material, and is to be used with three titanium alloy bone screws included as part of the system.

    Device Description

    The Irix-A Lumbar Integrated Fusion System is a stand-alone intervertebral fusion device to restore biomechanical height and act as an aid in fusion of the lumbar spine in anterior discectomy procedures. The device is generally box-shaped with teeth on the superior and inferior faces of the drix-A implant is manufactured from both titanium alloy (Ti6Al4V) in accordance with ASTM F136 and Invibio PEEK-Optima LT1 in accordance with ASTM F2026, or from Ti6AMV titanium alloy alone. The device will be supplied with the option of having the superior and inferior surfaces of the device plasma coated with medical-grade commercially pure titanium (CP Ti) per ASTM F1580. The device is secured in location through the use of bone screws, also manufactured from titanium alloy (Ti6Al4V) per ASTM F136. The devices are provided in various sizes and screws are offered in multiple lengths to adjust for variations in patient anatomy.

    The CP-Ti coated devices will be sterile packed with the balance of system components being provided clean and non-sterile. The non-sterile components are to be sterilized by a healthcare professional using a steam autoclave in accordance with the instructions for use provided by X-spine Systems Inc., as well as the instructions provided by the manufacturer of the autoclave.

    AI/ML Overview

    The information provided describes the Irix-A™ Lumbar Integrated Fusion System, which is an intervertebral body fusion device, not a device that relies on AI algorithms or machine learning. Therefore, many of the requested categories related to acceptance criteria for AI/ML performance, such as sample sizes for test/training sets, ground truth establishment by experts, adjudication methods, and MRMC studies, are not applicable.

    The acceptance criteria and supporting study for this device are based on mechanical performance testing to demonstrate substantial equivalence to existing predicate devices.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySpecific Test/StandardAcceptance CriteriaReported Device Performance
    Mechanical PerformanceASTM F2077Must meet the requirements for intervertebral body fusion devices, including static and dynamic compression, and static and dynamic compression-shear."Substantially equivalent to predicate device performance and is capable of performing in accordance with its intended use." (Specific quantitative values not provided in summary).
    ASTM F2267Must meet the standard for measuring load-induced subsidence of an intervertebral body fusion device under static axial compression."Substantially equivalent to predicate device performance and is capable of performing in accordance with its intended use." (Specific quantitative values not provided in summary).
    Expulsion TestingThere is no cited standard, but the device must demonstrate acceptable resistance to expulsion.Performed as part of the submission, and results contributed to the overall finding of substantial equivalence. (Specific quantitative values not provided in summary).
    Material QualificationFDA Guidance & ASTM F1580For plasma coating (CP-Ti), full material performance qualification and characterization.Performed, and results contributed to the overall finding of substantial equivalence. (Specific details not provided in summary).
    Wear Debris AnalysisFor plasma coating, wear debris particulate analysis from dynamic compression-shear testing.Performed, and results contributed to the overall finding of substantial equivalence. (Specific details not provided in summary).

    2. Sample size used for the test set and the data provenance
    This is a medical device (spinal implant) and not an AI/ML device relying on a test set of data in the common sense. The "test set" refers to the physical devices and materials tested. The summary does not specify the exact number of units or samples tested for each mechanical test, but implies sufficient testing was conducted to meet the ASTM standards and satisfy FDA requirements for substantial equivalence.
    Data provenance: The testing was conducted by X-spine Systems, Inc. in Miamisburg, OH, USA.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
    Not applicable. The "ground truth" for this type of device is established by meeting engineering and mechanical standards, not by expert consensus on data interpretation. Performance is objectively measured against specified limits in the ASTM standards.

    4. Adjudication method for the test set
    Not applicable. Mechanical testing results are objective measurements against pre-defined engineering standards, not subjective interpretations 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
    Not applicable. This is not an AI/ML device, and thus no MRMC study involving human readers and AI assistance was performed.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
    Not applicable. This is a physical spinal implant, not an algorithm.

    7. The type of ground truth used
    The "ground truth" in this context is based on established engineering principles, materials science, and biomechanical performance standards (e.g., ASTM F2077, ASTM F2267). The device's performance is objectively measured against the requirements of these standards and compared to the performance of predicate devices.

    8. The sample size for the training set
    Not applicable. This is not an AI/ML device requiring a training set.

    9. How the ground truth for the training set was established
    Not applicable.

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