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510(k) Data Aggregation

    K Number
    K210427
    Date Cleared
    2021-04-20

    (68 days)

    Product Code
    Regulation Number
    888.3070
    Why did this record match?
    Device Name :

    M.U.S.T. Midline Cortical (MC) Screw System

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

    The M.U.S.T. Pedicle screws system is intended for posterior non-cervical pedicle fixation (T1-S2/ilium) and non-pedicle fixation, or anterolateral fixation (78-L5). These devices are indicated as an adjunct to fusion for all of 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; pseudoarthrosis; and failed previous fusion in skeletally mature patients.

    Device Description

    The M.U.S.T. Midline Cortical (MC) Screw System is intended to be used as part of the M.U.S.T. Pedicle Screw system (K12115, K132878, K141988, K153664, K162061, K171170, K171758, K193365) for the stabilization and the fusion of the lumbar and thoracic spine. The M.U.S.T. pedicle screw system includes cannulated or non-cannulated poly-axial pedicle screws (K121115, K132878, K153664), cannulated or non-cannulated mono-axial pedicle screws (K132878), set screws (K121115, K171758), straight and pre-bent rods (K12115, K141988, K162061), lateral connectors (K162061) and cross connectors (K132878, K193365). The M.U.S.T. pedicle screw system also includes the enhanced screws and rods designed for percutaneous surgery (K141988).

    The M.U.S.T. Midline Cortical (MC) Screw System introduce new polyaxial screws and reduction screws (solid and cannulated), developed with a focus on Midline Cortical Trajectory approach. The devices subject of this submission are:

    • M.U.S.T. MC polyaxial screws Solid
    • M.U.S.T. MC polyaxial screws Cannulated
    • M.U.S.T. MC polyaxial reduction screws Solid
    • M.U.S.T. MC polyaxial reduction screws Cannulated

    Intended purpose and the performance specification of the devices are equivalent to the ones of the current US cleared portfolio: polyaxial screws are already used in the MUST implant construct.

    The M.U.S.T. Midline Cortical (MC) Screws and the Inlay are manufactured from Ti-6Al-4V ELI (ISO 5832-3 Implants for surgery -Metallic materials - Part 3: Wrought titanium 6-vanadium alloy + ASTM F136 Standard Specification for Wrought Titanium-4Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications (UNS R56401); the Tulip and the Setscrew are made of Co-Cr-Mo alloy according to ISO 5832-12:2019, Implants for Surgery - Metallic materials -Part 3: Wrought cobalt-chromium-molybdenum alloy, the same material of the previous cleared M.U.S.T. Pedicle Screw (K153664, K121115, K171170).

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and study for the M.U.S.T. Midline Cortical (MC) Screw System:

    1. Table of acceptance criteria and the reported device performance:

    The provided document does not explicitly state specific quantitative acceptance criteria for many of its tests. Instead, it describes various tests performed and implies that the results of these tests met the necessary standards for substantial equivalence. For instance, mechanical evaluations were conducted "according to ASTM F1717-18" without specifying the pass/fail thresholds. The "geometrical analysis" was performed "to ensure that the implant has sufficient fixation" and "in comparison to approved and marketed implants," implying an acceptance of similarity or non-inferiority.

    To create a table, I will infer the performance reported based on the conclusion of substantial equivalence.

    Evaluation/TestAcceptance Criteria (Inferred)Reported Device Performance/Outcome
    Non-Clinical Studies
    DESIGN VALIDATION
    Wetlab (Surgical Technique)Satisfactory performance and usability by experienced surgeons according to the MUST MC surgical technique.Performed by 3 experienced surgeons according to MUST MC surgical technique; implies satisfactory validation.
    Geometrical Analysis (Implant Fixation)Sufficient fixation in bone, comparable to approved and marketed implants, concerning important thread dimensions.Performed in comparison to approved and marketed implants to ensure sufficient fixation; implies comparable and sufficient fixation.
    PERFORMANCE TESTING
    Worst Case Definition for ASTM F1717Identification of appropriate implant types and sizes representing the "worst case" for mechanical testing.Worst case defined for mechanical testing of the spinal construct in a vertebrectomy model.
    Mechanical Evaluation (Static Compression Bending)Compliance with ASTM F1717-18 standard test methods for spinal implant constructs in a vertebrectomy model. (Implicitly meeting or exceeding predicate's performance or standard thresholds).Performed according to ASTM F1717-18; implies compliance and satisfactory mechanical performance.
    Mechanical Evaluation (Dynamic Compression Bending)Compliance with ASTM F1717-18 standard test methods for spinal implant constructs in a vertebrectomy model. (Implicitly meeting or exceeding predicate's performance or standard thresholds).Performed according to ASTM F1717-18; implies compliance and satisfactory mechanical performance.
    Mechanical Evaluation (Static Torsion)Compliance with ASTM F1717-18 standard test methods for spinal implant constructs in a vertebrectomy model. (Implicitly meeting or exceeding predicate's performance or standard thresholds).Performed according to ASTM F1717-18; implies compliance and satisfactory mechanical performance.
    PYROGENICITY
    Endotoxins-Mediated Pyrogenicity Assessment (Implants)Assessment indicating acceptable pyrogenicity levels as per documented reports. (Implicitly non-pyrogenic)."ENDOTOXINS-MEDIATED PYROGENICITY ASSESSMENT REPORT FOR: 'MUST PEDICLE SCREWS IMPLANTS SURGICAL KITS'" (TF VI-PS-01, RAS-01.008.141 Rev. 5, Dated: October 17 2020) was provided.
    Endotoxins-Mediated Pyrogenicity Assessment (MC ModularAssessment indicating acceptable pyrogenicity levels as per documented reports. (Implicitly non-pyrogenic)."ENDOTOXINS-MEDIATED PYROGENICITY ASSESSMENT FOR: 'MUST MC MODULAR TAP'" (TF VS-PS-01, RAS-01.008.260 Rev. 0, Dated: February 18 2020) was provided.

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

    • Sample Size:
      • Wetlab (Surgical Technique): The "cadaver labs were performed by 3 experienced surgeons." This refers to the number of users of the devices, not a number of distinct device units or anatomical samples tested. The number of cadavers used is not specified.
      • Geometrical Analysis: Not specified, but it would involve measurements of the (new) M.U.S.T. MC implants and approved/marketed implants.
      • Mechanical Performance Testing (ASTM F1717): Not specified. ASTM F1717 standards generally define specific sample sizes (e.g., minimum of 5 samples per test condition for static tests, 3-6 for dynamic fatigue). The document states "Worst Case definition... for mechanical testing," implying specific samples were chosen.
      • Pyrogenicity Assessment: Not specified, but would align with standard biological testing protocols.
    • Data Provenance (Country of Origin, Retrospective/Prospective): Not explicitly stated. These were non-clinical studies conducted for regulatory submission. Given the manufacturer is Medacta International SA (Switzerland) and its US counterpart Medacta USA, the testing could have been conducted in any accredited lab globally. They are prospective tests conducted on the device components and system.

    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):

    • Number of Experts: 3 experienced surgeons were used for the wetlab (surgical technique validation).
    • Qualifications of Experts: They are described as "experienced surgeons." No further detailed qualifications (e.g., years of experience, specific sub-specialty) are provided in this document.

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

    The document mentions "3 experienced surgeons" performed the wetlab. However, it does not describe an adjudication method for their observations or findings. It simply states the lab was performed "according to MUST MC surgical technique," implying their use was for validation of the technique and device performance, not necessarily for a consensus-driven "ground truth" establishment in the typical sense of diagnostic accuracy.

    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 device is a medical implant (spinal screw system), not an AI/software device that assists human readers. Therefore, the concept of "human readers improve with AI vs without AI assistance" does not apply to this submission.

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

    • No, a standalone (algorithm only) performance study was NOT done.
    • As explained above, this is a physical medical implant, not a software algorithm.

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

    For the non-clinical studies:

    • Wetlab: "Performance by 3 experienced surgeons according to MUST MC surgical technique" implies the ground truth for surgical technique validation was established through expert application/observation and adherence to predefined protocols.
    • Geometrical Analysis: Ground truth was the geometric properties of approved and marketed implants used for comparison, and engineering specifications.
    • Mechanical Testing (ASTM F1717): Ground truth was defined by the requirements and methodologies of the ASTM F1717-18 standard and comparisons to the mechanical characteristics of the predicate device.
    • Pyrogenicity: Ground truth was established by standard biological assessment methods for endotoxins, validated against established limits.

    8. The sample size for the training set:

    • Not applicable. This device is a physical medical implant, not an AI/machine learning model that requires a training set.

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

    • Not applicable. (See point 8).
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